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France - Zimmer: “Commissionaire” Agent Is Not a Permanent Establishment

Country:
France
Author:
B. Gouthière
Issue:
European Taxation, 2010 (Volume 50), No 8
Published:
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.
 
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