Facts and points of discussion
In 2002, the American company Google Inc. had concluded a marketing and services agreement (MSA) with the French subsidiary Google France SARL (for support and marketing services in France). In 2004 Google transferred the marketing and services agreement to Google Ireland Limited, residing in Ireland. The MSA included the performance of digital services through the online advertising platform of Google (AdWords). Under the MSA Google France SARL provided commercial assistance and advice to French customers who used the AdWords service. The services provided in France were invoiced by Google Ireland Limited. Hereafter a summarized group overview is provided.