Under Article 24 (8) of MiFID 2 and Article L. 533-12-3 of the CMF, asset management companies shall retrocede to its investors any fee, commission or monetary benefit received when providing the portfolio management investment service. The Tax Administration (Direction de la Législation Fiscale) has indicated that these retrocessions will be treated as revenus de capitaux mobiliers and therefore be subject to the “flat tax” of 30% (covering taxes and social security contributions). 

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