A new stage has just been reached in a famous tax dispute: that of the “precompte movable”, this tax on dividends instituted in 1965 and abolished in 2005. For two decades, French companies have been battling before the courts to obtain reimbursement of this tax which they believe they have paid unduly. On Wednesday, the Council of State rendered a decision in the Schneider Electric and Air Liquide files.
It partially overturned two judgments of the Administrative Court of Appeal of Versailles which, in 2020, had revised upwards the reimbursements granted at first instance to the two groups for 2002 and 2003. In doing so, it dismissed Schneider Electric’s appeal and Air Liquide but also applied the case law in force.