the French banking federation requests the Council of State

The banks are fighting back. The French banking federation (FBF) announced on Thursday March 30 that it had filed an appeal with the Council of State against the position of the tax authorities on the taxation of dividends for foreign holders of shares in listed French companies. . This question is at the heart of the scheme called “CumCum”. “We filed an appeal with the Council of State today”a spokesperson for the FBF told AFP, confirming information from the financial agency Bloomberg.

The aim is to have a legal framework “clear and consistent” on the subject, two days after searches in five major banks in France suspected of having participated in this tax scheme. Presented as “a subject of controversy between banking establishments and the tax administration (…) for several years”the intermediary role of five banks in the taxation in France of dividends from shares of French companies is the subject of several investigations opened in mid-December 2021 by the National Financial Prosecutor’s Office (PNF).

A remedy “completely independent of the procedures in progress”, assures the FBF

The investigations led Tuesday morning to an operation of unprecedented scale, mobilizing 16 magistrates (out of 19 in post) from the PNF, 150 investigators (out of more than 250 in post) from the judicial finance investigation service (SEJF), as well than six German prosecutors from the Cologne public prosecutor’s office. Five financial institutions are targeted: BNP Paribas, Exane (fund manager, subsidiary of BNP), Société Générale, Natixis and HSBC.

If he arrives two days after the searches, the filing of this appeal “for excess of power” East “completely independent of ongoing legal proceedings”specifies the FBF, which does not comment further on this subject.