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