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French Supreme Administrative Court finds taxpayer in ValueClick case used an agency permanent establishment to sell online advertising services in France through local subsidiary electrónico Bob Michel

By: Michel, Bob.
Material type: ArticleArticlePublisher: 2021Subject(s): ESTABLECIMIENTO PERMANENTE | SUCURSALES | CONTRATO DE AGENCIA | SERVICIOS DIGITALES | ELUSION FISCAL | FRANCIA | JURISPRUDENCIA In: Bulletin for International Taxation v. 75, n. 4, April 2021, p.154-161Summary: 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.
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Disponible únicamente en formato electrónico.

Resumen.

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.

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