On 11 December 2020, the French Supreme Administrative Court ruled that Valueclick International, an Irish company in the digital sector, had a permanent establishment in France, for purposes of both corporate income tax (CIT) and value-added tax (VAT), through another Valueclick subsidiary, Valueclick France. In this episode of TMT Talk, Kate Alexander, Ariane Calloud, and Erik Christenson review this landmark decision from the perspectives of French and US tax law. Listen to our panel of experts explore both the…
Part of the b:INFORM 2015/2016 Cloud Survey Trend Series1. Taxable Presence. During 2015, the OECD made significant progress in its initiative known as BEPS (Base Erosion and Profit Shifting), and issued Final Reports in October. In the BEPS Report on Action 1: Addressing the Tax Challenges of the Digital Economy, the OECD essentially declined to create any new rules for that segment of the economy. In light of this, we donât expect that international tax…