Abstract
In this year 2022, the creation of a new international tax order seems to be emerging. The OECD Pillar 1 and Pillar 2 solution adopted by nearly 140 States constitutes a sharp break with the traditional frameworks for distributing taxing rights. The reasons that prompted the OECD Inclusive Framework to act are well known. The permanent establishment and the arm's length principle would no longer make it possible in a digitized economy to ensure a fair distribution of the tax base between States. While the states with privileged taxation, hosting the headquarters of larger corporate groups, would be the main beneficiaries of this situation, the states of consumption would be the main victims. The undertaking to overhaul international tax law would be all the more urgent as the deterioration of the alliance between the citizen and the tax authorities continues to increase as more and more players settle in the markets. Internet powers such as GAFAM, NATU or BATX. The pronounced taste of these "global" multinational companies for "libertarianism", indeed leads to doubting the validity of a centralization of sovereign attributes at the level of the State, and suggests the institution of a new world. which would be structured horizontally outside of any state intervention.However, the path of a break with the current system cannot be chosen without a demonstration of the obsolescence of the legal bases for the distribution of tax rights. Thus, this thesis aims to study precisely the norms on which the distribution of tax jurisdiction and profits between related companies are based, their mobilization by the tax administration and their interpretation by the French administrative judge, in order to to determine whether the recurring judgment of obsolescence of which they are victims is justified.