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

The Paris Administrative Court of Appeals issued a revised decision on 8 December 2021 regarding the interpretation of the permanent establishment provisions of the 1968 France-Ireland tax treaty. The revised decision follows a December 2020 decision of the French Supreme Administrative Court that had annulled the Court of Appeals' prior decision in the case.

The case concerned an Irish principal (ValueClick International, later renamed Conversant International), which concluded online ad c…