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French Administrative Supreme Court expands its definition of a dependent agent constitutive of a permanent establishment

|Tax Alerts, Legislation & Policy, National/Federal Taxation, Treaties, OECD|France, Ireland
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 International (subsequently renamed Conversant International Ltd.), an Irish entity which carried ou…

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