France: Deadline extended for withholding tax refund claims
New decree aligns withholding tax refund claims with the general two-year limitation period.
The French government on July 29, 2026, published a decree extending the deadline for submitting withholding tax (WHT) refund claims.
Under prior rules, taxpayers generally were required to submit a WHT refund claim by December 31 of the year following the year in which the tax was withheld. The decree repeals that special one-year limitation period and aligns WHT refund claims with the general two-year deadline applicable to other taxes.
The change follows a February 16, 2026 decision of the French Supreme Administrative Court, which held that the shorter filing deadline was unlawful. The decree became effective on July 30, 2026.
Read an August 2026 report prepared by KPMG's EU Tax Centre