France vs Société Lifestand vivre debout, 15 April 2016, CE

In the case of Société Lifestand vivre debout, the Court considered that there was economic control in a situation where the rent for Swiss premises used by a Swiss entity was paid by a French company.

The functions related to the activity of the Swiss company were actually performed by the French company. The French manager managed the Swiss company.

Consequently, the transactions conducted between these two entities needed to comply with transfer pricing rules.

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Société Lifestand vivre debout _15_04_2016_CE no 372097