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Italy - Commissionaire Permanent Establishment: Possible Repercussions of the Zimmer Case

C. Galli
International Transfer Pricing Journal, 2011 (Volume 18), No 1
24 December 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 Italy.
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