Conseil d'Etat recharacterises the existence of a PE in the digital economy
The French Administrative Supreme Court ( Conseil d’Etat) has characterised the existence of a permanent establishment (PE), adopting a broad interpretation of ‘dependent agent’, with regards to a company based in Ireland operating in the sector of the digital economy. This case overturned the decision of the Paris Administrative Court of Appeal. Background Valueclick is a US-based group operating in the digital economy, whose activity consists of providing internet advertising solutions ...
United States France General Hugo Levit Nicolas Duboille Valueclick International Conversant International Ltd The Irish
Source: internationaltaxreview.com