[Tax Alert] Surcharge of 3% on dividends: The exemption in favor of tax consolidated groups contrary to the French constitution

The constitutional Court rendered its decision n°2016-571 QPC on September 30, 2016 and decided that the exemption of the 3% tax for distributions made inside a tax consolidated group provided for in Article 235 ter ZCA I 1° of the French Tax Code is not constitutional.

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