
In July 2017, we reported that Google was escaping a tax adjustment of 1.15 billion euros in France. The Minister of Public Accounts, Gerald Darmanin, then immediately appealed to the Paris Administrative Court of Appeal to challenge the decision of the court. We learn today that it confirmed April 25, 2019 the cancellation of this tax adjustment, reports Le Monde.
Google escapes a tax adjustment of 1.15 billion euros in France
The court ruled in favor of the Mountain View firm on the same arguments as in the trial judgment. In particular, Google believes it does not have to declare its income and profits (and therefore pay taxes) in France because the sale of advertising on this market passes through its Irish subsidiary Google Ireland Limited (GIL). Justice also supports the US giant on the fact that Google France is not able to manage this activity all by itself and he is only able to help the Irish subsidiary. It was also considered that Google Ireland Limited does not have a "permanent establishment" in France.
The French tax authority challenged this point of view by saying that employees in France play a decisive role in the sale of advertising space on the Google environment, including its search engine and site for sharing and streaming YouTube videos. But as the contracts are at the end of the process signed by GIL, this could not be proven.