Dividend taxation policy in Europe has traditionally been highly fragmented. France, for example, with its avoir fiscal tax credit established in 1965 to eliminate double tax on dividends, allows domestic shareholders to claim as much as 50% back on dividend tax. A similar system existed in Italy until the beginning of this year, also offering a 50% tax credit for investors.
This meant domestic investors in these countries could use their favourable tax position to engage in dividend arbitrage
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