Canada - Constructive Permanent Establishments: Canadian Comments on the Zimmer Case
- J.S. Wilkie
- International Transfer Pricing Journal, 2010 (Volume 17), No 5
- 12 August 2010
Part of the Comparative Survey. The French Supreme Administrative Court recently decided in the Zimmer case that a French subsidiary of a foreign parent company, which operated in France under French law as a commissionaire, did not constitute a taxable French permanent establishment in France of the foreign company. The case has been explained in "Zimmer Case: The Issue of the Deemed Existence of a Permanent Establishment Based on Status as a Commissionaire" by Mr Pierre-Jean Douvier and Ms Xenia Lordkipanidze (17 International Transfer Pricing Journal 4, 2010). Country report about this issue on Canada.