The Concept of Dependent Agent Permanent Establishment in Transfer Pricing Theory

The previous issues of the International Transfer Pricing Journal featured a number of country analyses on local consequences of the French Supreme Administrative Court decision in the Zimmer case. The Court held 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. Mr Louan Verdoner, who prepared the outline for the survey, now presents his own views on the matter.