Tag: Converted into a commissionaire

France vs. Zimmer Ltd., March 2010, Conseil D'Etat No. 304715, 308525

France vs. Zimmer Ltd., March 2010, Conseil D’Etat No. 304715, 308525

The French company, Zimmer SAS, distributed products for Zimmer Limited. In 1995 the company was converted into a commissionaire (acting in its own name but on behalf of Zimmer Ltd.). The French tax authorities argued that the commissionaire was taxable as a permanent establishment of the principal, because the commissionaire could bind the principal. The Court ruled that the commissionaire could not bind the principal. Therefore, the French commissionaire could not be a permanent establishment of the principal. Click here for translation France-vs-Zimmer-March-2010-case-nr-304715 ... Continue to full case