FORM 20-F THOMSON multimedia - Technicolor

This discussion is intended only as a descriptive summary and does not purport to be a
complete analysis or listing of all potential tax effects of the purchase, ownership or disposition of
the shares.
The following summary does not discuss the treatment of shares that are held by a resident of
France (except for purposes of illustration) or in connection with a permanent establishment or fixed
base through which a holder carries on business or performs personal services in France, or by a
person that owns, directly or indirectly, 5% or more of the stock of our company.
Taxation of Dividends on Shares
In France, dividends are paid out of after-tax income. French residents are entitled to a tax
credit, known as the avoir fiscal, in respect of dividends they receive from French companies.
Individuals are entitled to an avoir fiscal equal to 50% of the dividend. The avoir fiscal applicable to
corporate investors is currently generally equal to 15%, unless they hold at least 5% of the French
distributing company and meet the conditions to qualify under the French parent subsidiary regime,
in which case the avoir fiscal is equal to 50% of the dividend. Dividends paid to non-residents
normally are subject to a 25% French withholding tax and are not eligible for the benefit of the avoir
fiscal. However, non-resident holders that are entitled to and comply with the procedures for claiming
benefits under an applicable tax treaty may be subject to a reduced rate of withholding tax, and may
be entitled to benefit from a refund of the avoir fiscal, as described below.
France has entered into tax treaties with the following countries and Territoires d’Outre-Mer
under which qualifying residents are generally entitled to obtain from the French tax authorities a
reduction (generally to 15%) of the French dividend withholding tax and a refund of the avoir fiscal
(net of applicable withholding tax). Some of the treaties listed below contain specific limitations on
the ability of corporate holders to receive payments in respect of the avoir fiscal, or provide that such
payments are available only to individuals.
Australia Italy Niger
Austria Ivory Coast Norway
Belgium Japan Pakistan
Bolivia Latvia Saint-Pierre et Miquelon
Brazil Lithuania Senegal
Burkina Faso Luxembourg Singapore
Cameroon Malaysia South Korea
Canada Mali Spain
Estonia Malta Sweden
Finland Mauritius Switzerland
Gabon Mayotte Togo
Germany (1)
Mexico Turkey
Ghana Namibia Ukraine
Iceland Netherlands United Kingdom
India New Caledonia United States of America
Israel New Zealand Venezuela
(1) According to a common statement of the French and German tax authorities dated July 13, 2001, dividends paid to
German resident holders other than individuals as of January 1, 2001 no longer give right to the avoir fiscal. As regards
German resident individuals, a supplementary agreement to the tax treaty between France and Germany was signed by
the French Republic and the Federal Republic of Germany on December 20, 2001, which provides that German resident
holders, including German resident individual holders, should no longer be entitled to the avoir fiscal. Such supplementary
agreement has not yet been adopted but, if adopted, should apply retroactively as of January 1, 2002.
If a non-resident holder establishes its entitlement to treaty benefits prior to the payment of a
dividend, then French tax generally will be withheld at the reduced rate provided under the treaty.
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