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 for website publishers and advertisers. The groups’ operations in Europe were carried out by its I...
Source: internationaltaxreview.com