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The Resource Revenus de capitaux mobiliers : retenue à la source (CGI, art. 119 bis-2)

Revenus de capitaux mobiliers : retenue à la source (CGI, art. 119 bis-2)

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The item Revenus de capitaux mobiliers : retenue à la source (CGI, art. 119 bis-2) represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.
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Summary: Decision of Appeals Court of Paris under which constructive dividends paid to Dutch resident are exclusively taxable in the Netherlands as they are not covered by the definition of dividends under the treaty but by the "other income" article. In the same decision, the Court held that constructive dividends paid to Saudi shareholders may be taxed in France eventhough they are not covered by the definition of dividends under the treaty (France-Saudi treaty contains no "other income" clause)

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Label: Revenus de capitaux mobiliers : retenue à la source (CGI, art. 119 bis-2)

Title: Revenus de capitaux mobiliers : retenue à la source (CGI, art. 119 bis-2)

Summary: Decision of Appeals Court of Paris under which constructive dividends paid to Dutch resident are exclusively taxable in the Netherlands as they are not covered by the definition of dividends under the treaty but by the "other income" article. In the same decision, the Court held that constructive dividends paid to Saudi shareholders may be taxed in France eventhough they are not covered by the definition of dividends under the treaty (France-Saudi treaty contains no "other income" clause)