French use dawn raids to crack down on PEs
January 24, 2011
Sophie Ashley - TPW
The French tax authorities (FTA) have been conducting raids on the offices of French companies in an attempt to prove the existence of permanent establishments (PE).
The raids, which are carried out without notice, are governed by section L16B of the French Tax Procedure Code. The procedure was amended in 2008 to improve the rights of the taxpayer, further to a ruling issued by the European Court of Human Rights (Ravon, February 1 2008).
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