Delhi Tribunal decision shows PE question depends on facts not law

Matthew Gilleard

April 02, 2014

The Delhi Tribunal has ruled against the taxpayer in another case which highlights the service permanent establishment (PE) clause of India’s double tax treaties.

Unlock this article.

The content you are trying to view is exclusive to our subscribers.

To unlock this article:

Take a Free Trial or Login

More from across our site

McDonald’s court settlement makes case for TP reviews

The fast-food company’s tax settlement with French authorities strengthens the need for businesses to review their TP arrangements and documentation.

Leanna Reeves, June 30, 2022

Brazil’s tax authority unveils game-changing TP plan

The full ALP model will be adopted through a new TP regime, which is set to boost the country’s investments and tax certainty.

Leanna Reeves, June 30, 2022

Experts say UK online sales tax would hold back businesses

Tax professionals have called on the UK government to reconsider its online sales tax as it would affect the economy at the worst time.

Siqalane Taho, June 29, 2022

E-invoicing compliance demands company attention: tax experts

Tax professionals have called on companies to act urgently to meet e-invoicing compliance targets as the EU plans to ramp up digitisation.

Siqalane Taho, June 29, 2022

Sponsored

Looking inward and outward – ITR’s India Special Focus launched

In the wake of India’s ambitious 25-year plan for economic growth, ITR has partnered with leading tax commentators to discuss what the future will look like for India and for the rest of the world.

Alice Jones, June 29, 2022

LONDON, UK - January 24th 2019: HMRC, Her Majesty's Revenue and

HMRC reports £32bn tax gap for FY 2020-21

But experts cast doubt on HMRC's data and believe COVID-19 would have increased the revenue shortfall.

Leanna Reeves, June 27, 2022

EY’s ‘Project Everest’ could boost business but not the brand

EY’s plan to separate its auditing and consulting businesses might lessen scrutiny from global regulators, but the brand identity could suffer, say sources.

Danish Mehboob, June 27, 2022

Row of microphones, flags, papers and other on long table in conference hall

Businesses call on G7 leaders for meaningful carbon taxes

Multinationals are asking world leaders to put a scale on carbon pricing to tackle climate change at the 48th G7 summit in Germany, from June 26 to 28.

Danish Mehboob, June 27, 2022

Budapest city skyline at Hungalian Parliament and Danube River,

Hungary rejects plan for 15% corporation tax rate

The state secretary told the French press that the country continues to oppose pillar two’s global minimum tax rate following an Ecofin meeting last week.

Leanna Reeves, June 24, 2022

This week in tax: Biden’s energy tax holiday runs out of gas?

This week the Biden administration has run into opposition over a proposal for a federal gas tax holiday, while the European Parliament has approved a plan for an EU carbon border mechanism.

Josh White, June 24, 2022