France: Guidelines on new dividend withholding tax rules
Effective January 1, 2026
The tax authorities published guidelines on the application of new dividend withholding tax rules effective January 1, 2026, under article 119 bis A (II) of the General Tax Code.
The rules require French companies to apply the domestic withholding tax rate on dividends paid to nonresidents in certain treaty jurisdictions where the treaty provides for a full exemption or zero rate.
Nonresident taxpayers may claim a refund if they demonstrate treaty residence and beneficial ownership, subject to strict documentation requirements.
The guidance also clarifies that French paying institutions must apply full withholding upfront and provide detailed reporting information to the tax authorities upon request.
For more information, contact a KPMG tax professional in France:
Cédric Philibert | cedricphilibert@kpmgavocats.fr
Marie-Pierre Hôo | mhoo@kpmgavocats.fr