SocGen Loses Row Over Offsets To Dividend Tax, ECJ Rules

Law360 (February 25, 2021, 8:24 PM EST) -- France didn't violate European Union law by limiting how much tax Societe Generale SA could offset against dividend taxes paid by its client companies to their home countries, the European Court of Justice said in a preliminary ruling Thursday.

By limiting the offset to the amount of French corporation tax a company paid on the dividends, instead of the amount the company paid to its home country, France treated domestic and foreign companies equally, the ECJ ruled.

The case arose from two types of financial transactions made by Societe Generale Asset Management Banque during 2004 and 2005, according to court documents. The...

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