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Aggressive tax optimization of non-cooperative multinationals synthesis company offering a digital service 3 5 entity based in a tax haven international authorities licence 1 international negociations intangible assets: : - brand - pantents - code - know-how ... - employees - activity - services - entrepreneurial risk ... few / no taxes paid in France paid services french government digital service company based outside france bill subsidiary in France (not a 'permanent establishment') 2 4 content analysis and personalization GTA s ad! cookies ad! 101110100111 010100111010 101100011100 1101010110... platform / API observations 1 2 3 4 5 multinationals with aggressive fiscal optimization obsolete notion difficult to quantify real value data supplied by the users are an input to the production line international decision is essential but will take at least 10 years Data Access data flow service provided cash flows infographic designed with the help of Nicolas Colin third-party services
