On December 11, 2020, the French Supreme Administrative Court (the ‘‘Court’’), sitting in tax ‘‘plenary’’ formation (the four chambers specialized in tax matters sit together when the Court rules on questions of principle, both complex and technical), issued a ruling in Conversant/ValueClick The Court addressed whether an Irish company, ValueClick International, which operates in the digital sector and benefits from services rendered by ValueClick France, a local company in its group, has a permanent establishment in France for purposes of corporate income tax (CIT) and value-added tax (VAT).
Source Baker & McKenzie
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