Au regard d'un nouvel arrêt de la CJCE, Bercy devrait retravailler sa doctrine concernant la retenue à la source sur les dividendes distribuées
Auteur | Legal News |
Le 8 novembre 2007, la Cour de justice des communautés européennes (CJCE) rendait une décision dans laquelle elle contestait une nouvelle fois la retenue à la source des dividendes distribués. Ainsi, après avoir sanctionné en 2006 le mécanisme français de taxation des dividendes sortants (arrêt Denkavit), elle a cette fois-ci sanctionné le mécanisme néerlandais. Applicable aux autres régimes fiscaux étrangers, cette décision élargit donc le champ des réclamations introduites après l'arrêt de 2006. Le ministère des Finances devra donc retravailler sa doctrine à la lumière de cette nouvelle décision européenne. En effet, suite à l'arrêt Denkavit, l'administration fiscale avait publié une instruction fiscale supprimant seulement la retenue à la source sur les dividendes versés aux entreprises basées dans l'EEE, hors Liechtenstein, ayant une participation supérieure à 5 % du capital de la société distributrice. Or, cette position ne satisfait pas les spécialistes, qui estiment...
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