Part 1 - AL-Tax

Table 9.3 Tax treatment of company distributions in EU-15 countries (2005)Classical system (unmodified – modified) Imputation system Participation exemption(partial – full)Austria Individuals and portfolio corporate shareholders: Substantial corporateA final withholding tax is imposed on the gross shareholders: 100%.distribution.Belgium Individuals: Dividends are taxable in the name of the Corporate shareholders: 95%.individual shareholders.Denmark Resident portfolio shareholders and individual Resident substantial corporateshareholders on dividends: Reduced income tax rates. shareholders: 100%.Finland Individuals: If a listed company distributes dividends, Corporate shareholders: 100%.70% (57% in 2005) of the total amount of thedividend is considered as capital income, while the restis tax exempt.Nonlisted companies may distribute tax-exemptdividends in an amount corresponding to 9% annualyield on the net worth of the company.225France Individuals: Dividends paid to resident individuals from Parent companies with at least1 January 2005 (and assessed to tax in 2006) no 5% shareholdings: 95%.longer carry an imputation credit. Instead, the dividendsare assessed to income tax, but only for 50% of theiramount.Minority shareholders with generally under5% shareholdings: Pure classical system.(Continued)