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France Seeks EUR 1.6 Billion in Back Taxes and Penalties from Google

26 February 2016

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France-Ireland

The French Tax Administration has reportedly issued a reassessment of EUR 1.6 billion to Google, including EUR 1 billion in back taxes and EUR 600 million in late interest and penalties. The reassessment concerns Google's online advertising business in France, which involves Google Ireland concluding contracts with French advertisers, while Google France is only remunerated a service fee based on a services contract between the two entities. The French tax administration disputed the attribution of the French-source income to Google Ireland rather than Google France on the basis of the transfer prices applied and the contention that the French entity...