Abstract
In this article, the author comments on the French Supreme Court’s Decision in Conversant, which addresses the test for determining whether a dependent agent permanent establishment (DAPE) exists. The author, after providing background details on the facts of the case and an historical overview of the DAPE provision, shows how the decision is consistent with previous decisions of the Court and the economic principles that underlie the international tax system originally established by the OECD Model.
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