OrbitaxFrench Court of Appeals Holds Irish Digital Marketing Company does Not have PE in France under Ireland-France Tax Treaty
|Treaty Development|France-Ireland
On 1 March 2018, the Paris administrative court of appeals issued its decision concerning whether an Irish subsidiary of U.S.-based ValueClick Inc. (now Conversant), a digital marketing company, had a permanent establishment in France.
The case involved Ireland-based ValueClick International Ltd. (ValueClick Ireland), which entered into a services agreement with another ValueClick subsidiary,…
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