Faced with the advanced tax optimization through Ireland and Bermuda and a paltry declaration of profit for its activity in France, the US giant Google had been summoned by the French tax authorities to pay 1.15 billion euros.
The American company had replied that its French subsidiary was not an emanation of Google Ireland Limited, which recovers the profits of European activities and has only a role of assistance, without the possibility of direct action on the sale of advertisements on the French market.
They do not have a "permanent organization" in France, Google Ireland is therefore not in principle taxable and Google France, which has only an advisory role, cannot be directly connected on this point.
This vision, which had been notified at first instance, was the subject of an appeal by the Minister of Public Accounts Gérald Darmanin in 2017. The Court of Administrative Appeal in Paris has just issued a second verdict in five the original decision … and confirms that Google is not required to pay the requested 1.15 billion euros.
With this confirmation of the decision, it will be difficult for the tax administration to claim arrears, even in the form of a "settlement agreement" raised by Darmanin.