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

On 11 December 2020, the French Supreme Administrative Court (Conseil d'Etat) issued a decision regarding the interpretation of the permanent establishment provisions of the 1968 France-Ireland tax treaty. The case involved Ireland-based ValueClick International Ltd. (now Conversant International Ltd.), which entered into a services agreement with another ValueClick subsidiary, ValueClick France, for the performance of marketing and administrative services. The French tax authority held that…