I checked the shorts on GOOG after I posted this and they were not out of the ordinary. I guess Alaphabet (Google) just shits money.
If your sale is made from France but payment is made to you at your Ireland Headquarters Google would have situs in Ireland -- the French don't see it that way ... They say the income generated in France has Income tax due
The French government is arguing Taxable Situs?
Quote:
Taxable Situs
The location where charges may be levied upon Personal Property by a government, pursuant to provisions of its tax laws.The situs of property for tax purposes is determined on the basis of whether the state imposing the tax has adequate contact with the property it is seeking to tax so that the particular tax is justified in fairness. Ordinarily personal property has its taxable situs in the place where its owner is domiciled or in the state where the owner has a true, fixed, and permanent home.
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With regard to employment laws in Google's French places of business this would be true.
With regard to VAT tax on Google's Digital Sales it is the Country of the buyer that gets the 'bounty.'
Impots.gouv.fr - Les procédures amiables
Little problem: Ireland and France have an income tax treaty.
Watch the stock price
