Revised approach to determining permanent establishment; income tax and VAT consequences

The Conseil d’Etat specified in its decision that the fact of not having technical means did not preclude the recognition of a permanent establishment, insofar as this condition was not relevant for companies in the digital sector (because they basically can locate their technical means wherever they want). In addition, the decision considers that the French employees had enough contractual power to reach decisions regarding the conclusion of contracts.

Source: KPMG

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