Dividend taxation
From a tax perspective, it is specified that the distribution of EUR 3.90 per share is subject to two separate tax regimes:
- up to EUR 2.53, the distribution constitutes a dividend.
- Tax treatment of dividends paid to beneficiaries who are French tax residents.
For individual beneficiaries who are tax residents in France, the dividend is subject upon payment to a social security tax of 17.2% and, in principle, to a mandatory non-definitive levy of 12.8%. These taxes are levied at source and are computed on the gross amount of the dividend. For its taxation in 2025, this dividend will fully be eligible for the 40% tax rebate referred to in Article 158.3.2° of the French Tax Code, where an express, global, and irrevocable election is made for taxation of its income from movable capital under the progressive scale of personal income tax. Where this option is not made, the dividend will be taxed at a final flat-rate income 12.8% and will not be eligible for this 40% rebate. In both cases, the levy of 12.8% borne at the time of the payment of the dividend is deducted from the individual income tax due. - Tax treatment of dividends paid to non-resident beneficiaries.
Dividends distributed from company profits to non-resident beneficiaries are subject to the following withholding taxes:- 12.8% for natural persons.
- 25% for legal entities.
- These withholding taxes may, however, be reduced or eliminated by international provisions, and in particular double taxation treaties which may exist between France and the country whose tax laws apply to the effective beneficiary of the dividend. The beneficiary of the dividend is invited to check with his tax advisor (i) whether such a double taxation treaty exists, (ii) the terms of this treaty and (iii) if the tax rate provided for in said treaty is lower than the rate applicable by default, the procedure for obtaining a refund of the overpayment and/or a tax credit.
- Tax treatment of dividends paid to beneficiaries who are French tax residents.
- up to EUR 1.37, the distribution constitutes a reimbursement of contribution in accordance with Article 112-1° of the French Tax Code since the profits and reserves other than the legal reserve have been previously distributed. As such, it is non-taxable under income tax for beneficiaries who are French tax residents, and is not subject to any withholding tax in France for non-resident beneficiaries.
Dividend taxation
From a tax perspective, it is specified that the distribution of EUR 3.90 per share is subject to two separate tax regimes:
- up to EUR 2.53, the distribution constitutes a dividend.
- Tax treatment of dividends paid to beneficiaries who are French tax residents.
For individual beneficiaries who are tax residents in France, the dividend is subject upon payment to a social security tax of 17.2% and, in principle, to a mandatory non-definitive levy of 12.8%. These taxes are levied at source and are computed on the gross amount of the dividend. For its taxation in 2025, this dividend will fully be eligible for the 40% tax rebate referred to in Article 158.3.2° of the French Tax Code, where an express, global, and irrevocable election is made for taxation of its income from movable capital under the progressive scale of personal income tax. Where this option is not made, the dividend will be taxed at a final flat-rate income 12.8% and will not be eligible for this 40% rebate. In both cases, the levy of 12.8% borne at the time of the payment of the dividend is deducted from the individual income tax due. - Tax treatment of dividends paid to non-resident beneficiaries.
Dividends distributed from company profits to non-resident beneficiaries are subject to the following withholding taxes:- 12.8% for natural persons.
- 25% for legal entities.
- These withholding taxes may, however, be reduced or eliminated by international provisions, and in particular double taxation treaties which may exist between France and the country whose tax laws apply to the effective beneficiary of the dividend. The beneficiary of the dividend is invited to check with his tax advisor (i) whether such a double taxation treaty exists, (ii) the terms of this treaty and (iii) if the tax rate provided for in said treaty is lower than the rate applicable by default, the procedure for obtaining a refund of the overpayment and/or a tax credit.
- Tax treatment of dividends paid to beneficiaries who are French tax residents.
- up to EUR 1.37, the distribution constitutes a reimbursement of contribution in accordance with Article 112-1° of the French Tax Code since the profits and reserves other than the legal reserve have been previously distributed. As such, it is non-taxable under income tax for beneficiaries who are French tax residents, and is not subject to any withholding tax in France for non-resident beneficiaries.
