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OpCo/Branch (Romania) Pre-tax profit 100 Tax @ 16% (16) Net profit 84 Parent (France)

Parent (France). Parent (France). Dividend 84 (no WHT). Profit remittance. OpCo (Romania). Branch (Romania). OpCo/Branch (Romania) Pre-tax profit 100 Tax @ 16% (16) Net profit 84 Parent (France) Subsidiary Branch Gross dividend 84 Gross income 100

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OpCo/Branch (Romania) Pre-tax profit 100 Tax @ 16% (16) Net profit 84 Parent (France)

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  1. Parent (France) Parent (France) Dividend 84 (no WHT) Profit remittance OpCo (Romania) Branch (Romania) OpCo/Branch (Romania) Pre-tax profit 100 Tax @ 16% (16) Net profit 84 Parent (France) SubsidiaryBranch Gross dividend 84 Gross income 100 Foreign tax (WHT) - Foreign tax (16) Taxable dividend (5%) 4.2 Taxable income 0 Tax @ 33.33% (1.4) Tax @ 33.33% 0 Foreign tax credit - Foreign tax credit 0 Domestic tax (1.4) Domestic tax 0 Net profit 82.6 Net profit 84

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