Fixed Establishment And The Internet Under French Law

It is useful to know when a website is considered as a fixed – or permanent - establishment (“établissement stable”) under French law. Indeed, this qualification has important tax consequences since e-commerce companies will only pay income taxes on the countries where these companies have fixed establishments.

The following questions have been addressed in this article:

What are the characteristics of a fixed – or permanent - establishment?
According to the prevalent view in France, is the website of a foreign company hosted in France a fixed establishment?
According to the OECD, when does an e-commerce company have a fixed establishment?

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