Today, the Court of Justice of the European Union released its decision in Groupe Steria SCA v. Ministère des Finances et des Comptes publics (C-386/14).  The court concluded that the French tax rule granting a full tax exemption on dividends only where the dividends are received from a company belonging to the same tax-integrated group (i.e., a fiscal unity) is an impermissible restriction on the freedom of establishment.  Because French parent companies cannot form a fiscal unity with their non-French subsidiaries, the full tax exemption is effectively unavailable for dividends from subsidiaries established in other EU member states.