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France - Zimmer Case: The Issue of the Deemed Existence of a Permanent Establishment Based on Status as a Commissionaire

Country:
France
Author:
P.-J. Douvier; X. Lordkipanidze
Issue:
International Transfer Pricing Journal, 2010 (Volume 17), No 4
Published:
14 June 2010
In a recent decision, the Council of State held that a commissionaire acting in the ordinary course of its business does not trigger the existence of a permanent establishment in France. This decision has been welcomed as restoring legal certainty for those doing business in France.
 
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