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Further to recent case law, Nicolas Duboille and Hugo Levit of Sumerson, discuss the potential use of alternative legally bound tools in the context of management packages that may be efficient from a tax and social contribution perspective.
Nicolas Duboille and Hugo Levit of Sumerson examine the taxation of real estate capital gains in France by non-residents and consider a case when the seller is a Delaware corporation.
Nicolas Duboille and Hugo Levit of Sumerson examine the taxation of real estate capital gains in France by non-residents and consider a case when the seller is a Delaware corporation.
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 for website publishers and advertisers. The groups’ operations in Europe were carried out by its I...