Nature of the Transaction
Vivendi recently completed a spin-off, distributing shares in three newly separated entities—Canal+, Havas N.V., and Louis Hachette Group—to its existing shareholders, on a one-for-one basis for each Vivendi share held.
The distribution of these shares to Vivendi investors was structured as a special dividend paid in kind. Under French tax law, €4.27 of the value of this distribution is considered taxable, and non-resident investors are subject to 25% withholding tax on that amount—resulting in a €1.0675 per share deduction.
Depending on the investor’s country of residence and tax status, a portion or the full amount of the withholding tax may be recoverable.
Despite the material value at stake, the non-standard classification of spin-offs means these events are frequently overlooked in traditional withholding tax recovery processes.
Why This Opportunity May Be Missed
Spin-offs—particularly those structured as dividends-in-kind—may not be clearly flagged.
Without specialist oversight, this type of event can be missed entirely.
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Time-Sensitive: France's 2-Year Statute Applies
French withholding tax reclaims are subject to a strict two-year limitation period from the end of the calendar year in which the income was received. This makes prompt action essential—both to secure eligibility and to enable faster refunds and reinvestment.
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How WTax Protects Your Position
At WTax, we deliver withholding tax recovery services that go beyond standard processes. We monitor niche and complex income events—like spin-offs and special dividends—to ensure no reclaim opportunity is missed.
Key advantages of partnering with WTax:
✔ Proactive opportunity identification – Our global team monitors a wide range of income and event types across markets to uncover reclaim opportunities often missed by standard processes.
✔ End-to-end reclaim management— Trusted by 1,000+ institutional clients and powered by 250+ Experts, we manage everything from documentation through resolution.
✔ Proven track record—In a prior Vivendi spin-off (2021), WTax submitted over €37.5 million in claims, recovering up to 26.5% of the spin-off value depending on investor domicile and structure
Now is the time to confirm your reclaim entitlement. Contact WTax today.
