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…