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permanent establishment

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Permanent Establishment: Concept and Its Application in Indian Context

Income Tax : Understand Permanent Establishment in India, its types, and the legal framework. Learn about taxation laws, DTAA provisions, and k...

September 25, 2024 4170 Views 0 comment Print

Taxation in Digital Economy: Income Tax provisions in India vis-à-vis Permanent Establishment

Income Tax : Explore India's income tax provisions for the digital economy, focusing on the concept of Permanent Establishment and recent legal...

July 13, 2024 981 Views 0 comment Print

Equalisation Levy on Online / Digital Advertisement

Income Tax : Learn about India's Equalisation Levy, targeting digital transactions like online advertisements by foreign e-commerce firms. Unde...

July 2, 2024 396 Views 0 comment Print

BEPS Principles and MLI Framework in India’s PE Status under DTAA

Income Tax : Explore the impact of BEPS principles and MLI framework on India's Double Taxation Avoidance Agreements (DTAA). Detailed analysis ...

January 15, 2024 1590 Views 0 comment Print

Does Establishment of a Business Connection in India Indicate Presence of a Permanent Establishment for a Company?

Income Tax : Explore complexities of Business Connection and Permanent Establishment for companies in India. Understand tax implications, signi...

January 1, 2024 6327 Views 0 comment Print


Latest News


OECD releases a discussion draft on the definition of 'permanent establishment' in the OECD Model Tax Convention; CBDT invite Comments

Income Tax : The OECD Committee on Fiscal Affairs has proposed important and far-reaching changes to the Commentary on Article 5 (Permanent Est...

November 11, 2011 1132 Views 0 comment Print

MNC preferring dispute resolution panel to settle their disputes with Income tax department

Income Tax : A host of companies from Mumbai, said to be 367 in number and mostly multinational in nature, have moved the recently set up dispu...

May 11, 2010 445 Views 0 comment Print

Double Taxation Avoidance Agreement Signed Between India and Tajikistan

Income Tax : A Double Taxation Avoidance Agreement was signed between India and Tajikistan today, i.e. 20th November, 2008. The Agreement was s...

December 1, 2008 627 Views 0 comment Print


Latest Judiciary


Reimbursement of Salaries to Seconded Employees Does Not Constitute FTS

Corporate Law : Karnataka HC upholds Flipkart's stance on TDS under Section 195, ruling seconded employees' salaries as reimbursements, not taxabl...

March 16, 2025 318 Views 0 comment Print

Fresh Adjudication Ordered on TPO Adjustment in Subsidiary Transaction

Income Tax : Bangalore ITAT overturns AO's PE classification of QlikTech India, orders fresh review based on TPO order, addresses TDS and inter...

March 9, 2025 75 Views 0 comment Print

Mere operational links or subsidiary relationships do not confer PE status: Delhi HC

Income Tax : Delhi High Court examines Nokia Network OY’s Permanent Establishment (PE) status in India, addressing taxation on software reven...

February 24, 2025 516 Views 0 comment Print

Samsung India Not Permanent Establishment of Samsung Korea: Delhi HC

Income Tax : Delhi HC rules Samsung India not a 'Permanent Establishment' of Samsung Korea. No tax liability under India-Korea DTAA for seconde...

January 29, 2025 645 Views 0 comment Print

Indian Subsidiary Compensated at ALP Not a Dependent Agent PE: Delhi HC

Income Tax : Delhi HC rules Krones' Indian subsidiary is not a Dependent Agent PE, dismissing the tax authority's appeal....

October 11, 2024 219 Views 0 comment Print


Latest Notifications


Non residents having no PE in India exempted from section 206C(1G) TCS

Income Tax : CBDT notifies Section 206C (1G) of Income Tax Act shall not apply to a person (being a buyer) who is a non-resident & who does not...

August 17, 2022 3783 Views 0 comment Print

Amendment of Rules for Profit attribution to PE: CBDT invites comment

Income Tax : Public Consultation on the proposal for amendment of Rules for Profit attribution to Permanent (PE) Establishment invited by CBDT....

April 18, 2019 4422 Views 0 comment Print


Latest Posts in permanent establishment

Reimbursement of Salaries to Seconded Employees Does Not Constitute FTS

March 16, 2025 318 Views 0 comment Print

Karnataka HC upholds Flipkart’s stance on TDS under Section 195, ruling seconded employees’ salaries as reimbursements, not taxable income for Walmart Inc.

Fresh Adjudication Ordered on TPO Adjustment in Subsidiary Transaction

March 9, 2025 75 Views 0 comment Print

Bangalore ITAT overturns AO’s PE classification of QlikTech India, orders fresh review based on TPO order, addresses TDS and interest issues.

Mere operational links or subsidiary relationships do not confer PE status: Delhi HC

February 24, 2025 516 Views 0 comment Print

Delhi High Court examines Nokia Network OY’s Permanent Establishment (PE) status in India, addressing taxation on software revenue, interest income & vendor financing.

Samsung India Not Permanent Establishment of Samsung Korea: Delhi HC

January 29, 2025 645 Views 0 comment Print

Delhi HC rules Samsung India not a ‘Permanent Establishment’ of Samsung Korea. No tax liability under India-Korea DTAA for seconded employees’ roles.

Indian Subsidiary Compensated at ALP Not a Dependent Agent PE: Delhi HC

October 11, 2024 219 Views 0 comment Print

Delhi HC rules Krones’ Indian subsidiary is not a Dependent Agent PE, dismissing the tax authority’s appeal.

Permanent Establishment: Concept and Its Application in Indian Context

September 25, 2024 4170 Views 0 comment Print

Understand Permanent Establishment in India, its types, and the legal framework. Learn about taxation laws, DTAA provisions, and key judicial interpretations.

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

September 21, 2024 897 Views 0 comment Print

Delhi High Court clarifies taxability of profits attributed to a Permanent Establishment (PE) under the India-UAE DTAA, even when global losses are incurred.

Taxation in Digital Economy: Income Tax provisions in India vis-à-vis Permanent Establishment

July 13, 2024 981 Views 0 comment Print

Explore India’s income tax provisions for the digital economy, focusing on the concept of Permanent Establishment and recent legal developments.

Income Taxable Under FTS Requires Direct Enablement or Skill Transfer, Advisory Services Not Sufficient Without PE Connection

July 8, 2024 363 Views 0 comment Print

For income to be taxable under FTS, there must be a direct enablement or transfer of skills or knowledge, which mere advisory or consultancy services might not fulfill unless such services are directly connected with a PE.

Equalisation Levy on Online / Digital Advertisement

July 2, 2024 396 Views 0 comment Print

Learn about India’s Equalisation Levy, targeting digital transactions like online advertisements by foreign e-commerce firms. Understand applicability, compliance, and consequences.

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