The French Administrative Supreme Court has overturned Article 182 A of the French Tax Code (FTC).
The Article provides for the application of a withholding tax on French-source salaries, wages, pensions and life annuities paid to persons who are not domiciled in France for tax purposes.
Although this tax domicile is not expressly defined by reference to French domestic law or tax treaties, French tax doctrine indicates that tax residence within the...
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