Source State’s Right to Attribute Income to a PE Based on Global Income/Loss

Hyatt International Southwest Asia Ltd Vs Additional Director of Income Tax (Delhi High Court)

Source State’s right to attribute income to a Permanent Establishment (PE) based solely on the global income or loss incurred by a cross-border entity – With reference to the Hyatt International Southwest Asia Ltd Case

The Delhi High Court has emphatically held that Article 7 does not restrict the source State’s right to attribute income to a Permanent Establishment (PE) based solely on the global income or loss incurred by a cross-border enti

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