French Supreme Administrative Court Finds Taxpayer in ValueClick Case Used an Agency Permanent Establishment to Sell Online Advertising Services in France through Local Subsidiary

Journal
Michel, B.
France; International; Ireland; OECD; United States
Bulletin for International Taxation 2021 (Volume 75), No. 4
FormatPDF
EUR
40
| USD
45
(VAT excl.)

In this article, the author considers the implications of the recent decision of the French Conseil d’État (Supreme Administrative Court) regarding the recognition of a hidden agency permanent establishment that was used by the Irish company to sell online advertising services in France, aided by a local subsidiary.