OrbitaxTreaty between France and Switzerland – French Supreme Administrative Court holds Swiss resident taxable in France on payments for services performed in France but paid via UK company
|Treaty Development|France-Switzerland
The Supreme Administrative Court (Conseil d'Etat) on 28 March 2008 (CE, 9ème et 10ème sous-sections réunies, No. 271 366, A.) confirmed an earlier decision of the Court of Appeals of Paris of 19 April 2004 (CAA Paris, 10ème chambre, No. 00PA02248). Details of the decision No. 271 366, A. are summarized below.
(a) Facts. A, a Swiss resident, gave a concert perfor…
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