The French Administrative Court of Appeal of Toulouse Feb. 12 issued Decision No. 24TL01207, clarifying the rules on permanent establishments (PEs) and the taxation of distributed income for nonresident companies. The taxpayers, individuals who were partners and directors of a French and an Irish e-commerce company, sought discharge of additional individual income tax and social security contributions for 2014-2015, arguing that they weren’t French tax residents, that the Irish company had no PE in France, and that the tax authority overstated profits. The tax authority and the Administrative Court of Nimes denied the request. On appeal, the Administrative Court of ...