France - Zimmer Case: The Issue of the Deemed Existence of a Permanent Establishment Based on Status as a Commissionaire
- P.-J. Douvier; X. Lordkipanidze
- International Transfer Pricing Journal, 2010 (Volume 17), No 4
- 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.