Court springs PE debate back into life

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Cookies Settings

Court springs PE debate back into life

October 19 2011

In two separate judgments Delhi High Court ruled on the tax liability of Rolls Royce and Rolls Royce Singapore due to their operations in India. Common issue in both the matters was exposure to a permanent establishment (PE) in India and quantum of profits to be attributed to operations carried out by the PE in India. Sunil Jain of J Sagar & Associates investigates.

Unlock this content.

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

To unlock this content:

Take a Free Trial or Login

Topics

FeatureIndia Quarterly November 2011-January 2012 (September 2011)
more across site & shared bottom lb ros

More from across our site

Transfer Pricing
Business loss
Transfer pricing and loss situations
Defending loss situations in TP is not about denying the existence of losses but about showing, through proactive measures, that the losses reflect genuine commercial realities
Jelana Mihić Munjić, November 27 2025
Direct Tax
Rachel_Reeves_and_Keir_Starmer.jpg
UK Autumn Budget prompts mixed reactions from advisers
Further empowerment of HMRC enforcement has been praised, but the pre-Budget OBR leak was described as ‘shambolic’
Sam Sholli, November 26 2025
Direct Tax
AI in Tax Forum 2
Reflections on the ITR AI in Tax Forum 2025
Michel Braun of WTS Digital reviews ITR’s inaugural AI in tax event, and concludes that AI will enhance, not replace, the tax professional
Michel Braun, November 26 2025
Indirect Tax
Aerial view of Christ and Botafogo Bay from high angle.
Local advisers praise OECD paper on Brazil VAT reform
The report is solid and balanced as it correctly underscores the ambitious institutional redesign that Brazil has undertaken in adopting a dual VAT model, experts tell ITR
Sam Sholli, November 25 2025
Direct Tax
paulo da rocha resized.jpg
The unpredictable world of tax, with Paulo Vieira da Rocha
The Brazilian law firm partner warns against going independent too early, considers the weight of political pressure, and tells ITR what makes tax cool
November 25 2025
Direct Tax
London
Dear chancellor, follow the Irish model: a path to long-term prosperity
The lessons from Ireland are clear: selective, targeted, and credible fiscal incentives can unlock supply and investment
Chris Danes, November 24 2025
Indirect Tax
nitin argawal resized.jpg
‘Extinction of tax as we know it’: Nitin Agarwal’s in-house bible
The ITR in-house award winner delves into his dramatic novelisation of tax transformation, and declares that 'tax doesn’t need AI right now'
Tom Baker, November 24 2025
Direct Tax
Oslo, Norway - 24 September 2022: PricewaterhouseCoopers or PWC
A taxing week: The PwC tax leaks scandal isn’t just hurting PwC
Recent news of job cuts at EY is symptomatic of how the PwC controversy has tarnished the reputation of the entire ‘big four’
Sam Sholli, November 21 2025
Direct Tax
OECD building
This week in tax: One-year pillar two safe harbour extension being considered – reports
Experts reportedly discussed extending the safe harbour to 2027 to give countries more time to legislate; in other news, Baker McKenzie and Greenberg Traurig made senior tax hires
Sam Sholli, November 21 2025
Awards
wbl Americas 2026@4x.png
2026 Women in Business Law Americas Awards: submissions now open
Submit your nominations to this year's WIBL Americas Awards by January 23
Shailyn Tirado, November 20 2025
Gift this article