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TMT Talk Episode 34 – Tax Development: Permanent Establishment in France

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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 national implications and possible global impact of this ruling, which is particularly relevant to technology companies interested in entering the French market.

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Kate handles all aspects of cross-border tax structuring for UK-headed and non-UK headed groups. She is particularly knowledgeable in UK DPT provisions, CFC regime, loan relationship anti-avoidance provisions and the new interest limitation rules. She regularly assists multinational companies with the design of their global holding and financing structures.

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Ariane Calloud is a member of the Tax Practice Group in Baker McKenzie Paris. Prior to joining the Firm in 2007, Ms. Calloud worked in the tax department of Landwell & Associés (PwC) where she practiced corporate tax and international tax law.

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