Executive summaryOn 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 discussionValueclick International (subsequently renamed Conversant International Ltd.), an Irish entity which carried out digital marketing activities in Europe through local entities, concluded for the French market an intercompany service agreement with Valueclick France, a French related company. The latter was paid on a cost-plus basis for marketing assistance as well as...