French ruling that Irish digital services provider has no PE in France
On 1 March 2018, the Paris Administrative Court of Appeal ruled that Irish-resident company Conversant International Ltd, which provides digital marketing services in France with the assistance of a French sister company, does not have a permanent establishment (PE) in France and is therefore not taxable in that country.
The decision is based on the following arguments: Valueclick International Ltd did not have a PE in France within the meaning of article 2(9) of the France – Ireland Income Tax Treaty (1968) since the French sister company was neither a fixed place of business to the extent that all the services it provided were covered by the intercompany services agreement, nor a dependent agent of Valueclick International Ltd in so far as the French company was not authorised to conclude contracts in the name of Valueclick International Ltd.
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