On February 6, 2025, France adopted a new law aimed at combating tax fraud related to dividend taxation, particularly targeting the 'CumCum' scheme.

This scheme enables foreign shareholders of French companies to evade dividend taxes, often with the assistance of banks that benefit from these transactions.

However, the French Ministry of Economy, known as Bercy, is now accused of undermining this legal framework designed to tackle such tax fraud.

Jean-François Husson, the Senate's general rapporteur for the budget, has voiced significant concerns regarding government amendments that could perpetuate fraudulent practices like 'dividend arbitrage'.

The initial unanimous political support for the legislation has been shaken by clarifications from Bercy on April 17, 2025, which have raised doubts among lawmakers about the effectiveness of the new anti-fraud measures.

This legislation is critical, as the 'CumCum' scheme is estimated to cost France between €1.5 billion and €3 billion annually.