The Paris Administrative Tribunal issued a decision on 12 July 2017 finding that Google Ireland does not have a permanent establishment in France in relation to its Adwords services (search-based advertising). The case involved the French tax authority's determination that Google Ireland had a PE in France and was liable to tax (EUR 1.12 billion) for the period 2005 to 2010 based on the activities of its French subsidiary and the dependent agent provisions of the 1968 France-Ireland tax treat…