An update to my post of 11 July on this topic. One of my clients has pointed out to me that the French fiscal authorities have now issued guidance on how UCITs can obtain a 0% rate of French withholding tax.
More information can be found in the link below
(There's a rather better note from Ashurst Paris that I can't link to but you should be able to google)
As far as I am aware it is not possible for a life company investing in French equities to obtain the 0% rate via this UCITs route. There might be a case in European law that UK linked pension business holdings should not suffer French withholding tax at 15% but such claims seem to be hard to enforce in practise.
Accordingly,linked pension business investment in French assets via a UCIT will obtain a better rate of withholding than direct investment in equities. This is of course the reverse of the position for Dutch, German, Swiss and Belgium equities where direct pension business investment obtains a lower rate of withholding than investing via a UCIT.
A tax transparent fund holding collectives investing in France (and maybe Italy) but having direct investments in other European markets might square the circle but whether the cost or complexity involved would be worthwhile is unclear.
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