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CJEU judgment in de Ruyter

The CJEU gave its landmark decision on the de Ruyter case (C-623/13) published on 26 February 2015. Judges put an end to the application of the French social contributions on non-French tax residents that are subject to foreign social security schemes.

This milestone decision will have a significant impact for foreign individual investors that have been subject to 15.5% social contributions imposed on French-source property income (rental income and capital gains) since 2012.

The ruling will open doors for tax refunds. This means foreign property investors that have paid these additional social contributions in France on the sale of a French property or on French rental income may now claim back from the French tax authorities any French social contributions unduly paid over the last three years.

The CJEU decision: Since 2012 non-French tax residents have been subject to the French 15.5% social contributions so-called CSG-CRDS on their French-source...

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