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AAR on taxability of income from execution of contract in India by German company, having no PE in India
Case Law Details
- Case Name
- In re Pintsch Bamag (Authority for Advance Rulings)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Courts
- Advance Rulings
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A recent ruling of the Authority for Advance Rulings (AAR) [2009-TIOL-23-ARA-IT] in the case of Pintsch Bamag (Taxpayer). The issue before the AAR was whether the sub-contractor’s workplace and work duration should be considered in determining the existence of a permanent establishment (PE) of the Taxpayer, under the India-Germany Tax Treaty (Tax Treaty).
Considering the facts of the case, the AAR observed that the work carried out by the sub-contractor was independent of any control by the Taxpayer. Thus, the time spent by the subcontractor should not be considered in determining the ...
