Under article 115 quinquies of the French Tax Code, the profits of a French branch of a foreign company are deemed to be distributed to non-residents, and are therefore liable to a 25% withholding tax, known as the branch tax. However, the branch may make a claim for a refund of the branch tax computed on the French branch's profits exceeding the actual amount of dividends distributed by the foreign entity to non-French residents.
June 30 2000