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, other than the provision of services;
– or, in any event, where the person receiving the remuneration for the services is domiciled or established in a foreign State or territory outside France where it is subject to a privileged tax regime within the meaning mentioned in article 238 A.
II. The rules set out in I above also apply to persons domiciled outside France for services rendered in France.
III. The person who receives the remuneration for the services is jointly and severally liable, up to the amount of this remuneration, for the taxes owed by the person rendering the services.