For French tax residents
The distribution of EUR2.55 per share constitutes distributed income subject to a social security tax of 17.2% charged on the gross amount when paid. The gross amount of French-source dividends received by resident individuals will also be subject to a mandatory non-definitive levy at source of 12.8%, but exemption from this levy. In 2020, dividends will in principle be subject to a flat tax (“Prélèvement Forfaitaire Unique” – “PFU”) at the rate of 12.8% unless option for dividends to be subject to income tax at ordinary progressive rates. In such case, after applying a 40% (uncapped) allowance, only 60% of the dividends will be included in the taxable income, less any deductible charges and expenses. The above-mentioned levy at source of 12.8% will be imputed on the income tax that will be due in 2020 for income earned in 2019.
Tax treatment of dividends paid to non-residents
Dividends distributed out of the profits of the company to non-resident beneficiaries are subject to withholding taxes (income taxes) as follows:
- 12.8% for individuals,
- 30% for legal persons.
Such rates may however be overridden by international provisions, notably the double-tax avoidance agreements that may exist between France and the country whose tax laws apply to the beneficiary.
The beneficiary is invited to check with his tax advisor (i) whether such double-tax avoidance agreement exists, (ii) the terms of such agreement and, (iii) if the rate provided in the said agreement is lower than the 30% withheld by default, the procedure to obtain a refund of the excess amount withheld and/or a tax-credit.
Shareholders are invited to contact their usual advisors for further information about the applicable tax regime.