France: Foreign exchange losses related to dividends under participation exemption are fully deductible (Supreme Court decision)

Deduction is not limited to taxable portion of dividends.

Share
november 11, 2025

The Supreme Court on July 25, 2025, held that foreign exchange losses related to dividends under the participation exemption regime are fully deductible.

The court overturned the Court of Appeals' decision limiting the foreign exchange loss deduction to 5%, aligning it with the taxable portion of dividends.

The court clarified that, under French tax law, foreign exchange gains and losses are accounted for at their value on the payment date, allowing the full deduction of foreign exchange losses irrespective of the 95% dividend exemption.


For further information, contact a KPMG tax professional in France:

Marie-Pierre Hôo | mhoo@kpmgavocats.fr

Thank you!

Thank you for contacting KPMG. We will respond to you as soon as possible.

Contact KPMG

Use this form to submit general inquiries to KPMG. We will respond to you as soon as possible.
All fields with an asterisk (*) are required.

Job seekers

Visit our careers section or search our jobs database.

Submit RFP

Use the RFP submission form to detail the services KPMG can help assist you with.

Office locations

International hotline

You can confidentially report concerns to the KPMG International hotline

Press contacts

Do you need to speak with our Press Office? Here's how to get in touch.

Headline