EYFrench Administrative Supreme Court expands its definition of a dependent agent constitutive of a permanent establishment
|Tax Alerts, Legislation & Policy, Na ...|France, Ireland
Executive summary
On 11 December 2020,1 the French Administrative Supreme Court (Conseil d’Etat) ruled that an Irish tax resident entity performing digital marketing activities had a French permanent establishment, for corporate income tax purposes, through its French affiliate, whereas contracts with clients were not formerly concluded in France by the affiliate.
Detailed discussion
Valueclick Inter…
Continue Reading
