AAR on Determination of PE and other connected issues in Master Card Case

Master Card Asia Pacific Pte Ltd (AAR Delhi)

Determination of Permanent  Establishment and other connected issues

Issue- Whether the Applicant has a permanent establishment in India as regards the use of a global network and infrastructure to process card payment transactions for customers in India and as regards other related issues?

Held– The AAR has held that digital and other connected equipments can, depending on the business model, determine the formation of a permanent establishment of a non-resident enterprise in India. There are also other related issues which will have ramifications on the methodology of conducting business in India.

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