No French withholding tax on payments from French sources for services provided by a “totally exporting” Tunisian company

In line with previous court rulings, especially from the Conseil d’Etat, the administrative court of first instance of Paris confirms that a so-called “totally exporting” company is entitled to the benefits of the double taxation treaty between France and Tunisia. As a result, the French withholding tax of 1/3 does not apply to the compensation of services provided to a French business by such entity (administrative court of first instance of Paris, January 17, 2023, 19-11926/1-2, NR-Coms)

- Administrative court of first instance of Paris n°19-11926/1-2 (January 17, 2023)
Download