A liaison office of a foreign co identifying suppliers/ material is not a permanent establishment under Article 5 of India-USA DTAA

CA Suraj R. Agrawal A liaison office of a foreign company which identifies a manufacturer in India, negotiates the price, helps in choosing raw material to be used, ensures compliance with quality, acts as go-between, between the petitioner, ensuring compliance with Foreign Companies policies and the relevant laws of India by the suppliers and the seller or the manufacturer and gets material tested is not a ‘permanent establishment’ under Article 5 of India-USA DTAA. Facts of the case: The petitioner is a company incorporated in the United State of America (USA) and is a tax resident o...