In accordance with the provisions of Article 115 of the General Tax Code of France, (hereinafter CGI), profits made in France by foreign companies through a permanent establishment are presumed to be distributed to partners who do not have a tax domicile or registered office in France, and therefore are subject to the withholding tax referred to Article 119 bis, 2 CGI.
This deduction is provisionally liquidated on the total amount of French results available. It can therefore, at the request of a foreign company, be recalculated on the basis of the actually distributed amounts.
Clarification of the calculation of the withholding tax of foreign companies.docx
