French Court of Appeal Issues Revised Decision on the Interpretation of Permanent Establishment Provisions in Tax Treaty with Ireland

The Paris Administrative Court of Appeals issued a revised decision on 8 December 2021 regarding the interpretation of the permanent establishment provisions of the 1968 France-Ireland tax treaty. The revised decision follows a December 2020 decision of the French Supreme Administrative Court that had annulled the Court of Appeals' prior decision in the case.
The case concerned an Irish princ…
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