On 17 December 2015, the Court of Justice of the European Union (CJEU) ruled on a case referred by the Finance Court in Cologne, Germany concerning the treatment of the losses of an Austrian permanent establishment (PE) of a German company (Timac Agro) following the transfer of that PE to another group company in Austria.
Timac Agro is a company limited by shares that is governed by German law and belongs to a French group. From 1997 to 2005, it had been operating a PE situated i…