A hell of a shortfall ... According to several international media a tax scheme on dividends would have cost the tax authorities of ten countries, at least 140 billion euros for twenty years.

The survey published Thursday ensures that France, but also Germany and Belgium.

The amounts not received by these states are nearly three times higher than the first revelations dating back to 2018 from this consortium of sixteen media, called “CumEx Files”.

The amount, initially estimated at 55 billion euros, has been largely revised upwards, in particular because the revelations of Thursday relate to a longer investigation period, ranging from 2000 to 2020, details the French newspaper Le Monde, which makes part of the consortium.

How does this trick work?

Mainly targeted in these latest revelations of tax fraud on dividends concerning France, the practice known as "CumCum" in financial jargon.

This consists of avoiding taxation on dividends which must in principle be paid by foreign holders of shares of listed French companies.

To take advantage of the scheme, these owners of shares, small savers or large investment funds according to

Le Monde

, entrust their securities to a bank when the tax is collected, thus avoiding taxation.

The banks, for their part, play an intermediary role, while taking a commission from the holders of shares, the newspaper continues.

Banks kick in touch

The consortium's investigation also shows that four French banks, BNP Paribas, Société Générale, Natixis and Crédit Agricole via its subsidiary Cacib, were the subject of investigations by the tax administration in 2017 on the subject, and that these these have "accelerated" in recent months. "Verifying the conditions under which temporary sales of securities are carried out is naturally one of the subjects examined" by the tax authorities, reacted Crédit Agricole.

The group affirms that it "does not offer arrangements to its clients for the purpose of dividend arbitrage nor does it carry out dividend arbitrage transactions for its own account", but that it conducts hedging transactions " in compliance with the legal, fiscal and regulatory rules in force ”.

Solicited, Societe Generale and Natixis declined to comment on the revelations.

BNP Paribas did not respond to the requests immediately.

The French Ministry of Finance has not responded to the requests for the time being.

The French Banking Federation, for its part, affirmed that the situations cited in the article fall within the sovereign appreciation of the courts, adding that the banks "are among the largest contributors to French public finances".


Three years later, the abolition of the ISF struggles to show its positive effects on the French economy


Services: What tax credit are you entitled to as a private employer?

  • Belgium

  • Money

  • Germany

  • Bank

  • Taxation

  • Tax fraud

  • Fraud

  • Economy

Keywords: countries, tax authorities, practice, tax scheme, revelations, hell, shortfall, jargon, dividends, survey, france, media, french, amounts, owners