OrbitaxFrench Court of Appeals Holds CJEU Judgment on Definitive PE Losses Must be Applied
|Approved Changes|France
A recent decision of the Administrative Court of Appeal of Versailles has been published regarding the offset of definitive losses of a permanent establishment (branch) in Luxembourg by a French group. The case involved a French group parented by Financière SPIE Batignolles (FSB) SCA, which was solely liable for the tax due by the group. In December 2016, FSB requested the allocation of the de…