Non-resident reinsurance business profit has no tax implication in India

RGA International Reinsurance Company Ltd Vs ACIT (International Taxation) (ITAT Mumbai) ITAT Mumbai held that business profits earned by the assessee (non-resident) on account of the reinsurance business have no tax implications in India and existence of dependent agency permanent establishment is wholly tax neutral in India. Facts- The assessee is a company incorporated in and fiscally domiciled in Ireland and is admittedly entitled to the benefits of India Ireland Double Taxation Avoidance Agreement. The assessee is engaged in the business of providing reinsurance services to its clients in...