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Article 155 A of the French General Tax Code

I. Amounts received by a person domiciled or established outside France as remuneration for services rendered by one or more persons domiciled or established in France are taxable in the name of the latter: – either, where these persons directly or indirectly control the person who receives the remuneration for the services; – or, where they do not establish that this person predominantly carries on an industrial or commercial activity,…

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