Avoidance of Permanent Establishment (PE) status of Non-Residents are made through various arrangements. Company structures their business in way that status of PE can artificially be avoided. The definition of permanent establishment included in tax treaties is therefore crucial in determining whether a non-resident enterprise must pay income tax in another jurisdiction. Strategies used to […]
Section 172 of income tax act is a special provision which deals with levy and recovery tax from foreign shipping companies. It specifies that every foreign shipping company has to declare a certain percentage of profit on its freight income and pay tax on it.
Many countries limit the amount of interest expenses of multinational companies (MNC). An enterprise who has borrowed capital in form of loan from its associate enterprises can claim deduction of interest paid and payable to associated enterprises. Foreign companies have several models to infuse capital in its associated company situated in another country. Some may […]
