Supreme Court Holds That Commissionaire Structure Does Not Amount to a Permanent Establishment

Journal
Leegaard, T.
European Union
European Taxation 2012 (Volume 52), No. 6
FormatPDF
EUR
45
| USD
50 (VAT excl.)

In this note, the author comments on the recent decision of the Norwegian Supreme Court in Dell Products v. Government of Norway, wherein the court held that sales to Norway through a Norwegian affiliate through a commissionaire arrangement did not constitute an agency permanent establishment.