France vs. Google, April 2019, Administrative Court of Appeal, Case N° 17PA03065

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In this case the French tax administration argued that Google had a permenent establishment in France because the parent company in the US and its subsidiary in Ireland had been selling a service – online ads – to customers in France.

In 2017 the administrative court found that Google France did not have the capability to carry out the advertising activities on its own. Google Ireland Limited therefore did not have a permanent establishment in France.

The same conclution was reached i 2019 by the Administrative court of appeal.

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France vs Google April 2019, No 17PA03065,