France - Zimmer: “Commissionaire” Agent Is Not a Permanent Establishment
- B. Gouthière
- European Taxation, 2010 (Volume 50), No 8
- 30 June 2010
The author, in this article, analyses a recent decision of the French Supreme Administrative Court wherein it was held that a commissionaire agent, whose services were used by a UK principal, did not constitute a PE in France due to the fact that, from a legal standpoint, the commissionaire did not have the power to legally bind the principal.