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France Launches Tax Actions Against 13 Banks in ‘CumCum’ Dividend Probe

A recent settlement by Crédit Agricole signals a broader enforcement push following earlier raids by financial prosecutors.

Overview

  • Radio France reports that the Finance Ministry has opened tax procedures targeting 13 lenders over dividend-arbitrage operations.
  • Bercy declined to comment, after Economy Minister Éric Lombard in July cited reassessment actions against five institutions totaling €4.5 billion.
  • Crédit Agricole’s investment arm agreed in early September to pay €88.24 million in a judicial settlement, the first resolution in the French case.
  • Five firms—including BNP Paribas, Exane, Société Générale, Natixis, and HSBC—were searched in March 2023 as part of the national financial prosecutor’s investigation.
  • The CumCum practice involves temporarily transferring shares around dividend dates so non‑resident investors avoid withholding tax while banks collect fees, a practice the French Banking Federation says does not reflect systemic fraud.