#permanent establishment
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215 articlesIncome Tax
Income Tax
Does constitution of “Service PE” entail physical presence of foreign personnel in host country?
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Income Tax
Formula One…Whats the Game?
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Taxability of business done by NRI through Power of Attorney holder
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Agent without authority to conclude contracts cannot be termed PE
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Even in a composite contract, off-shore profits cannot be assessed by dept. without showing its attribution to PE
Income Tax
Income Tax
OECD releases a discussion draft on the definition of 'permanent establishment' in the OECD Model Tax Convention; CBDT invite Comments
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Income Tax
Taxpayer did not constitute a Construction PE under the DTAA as the contract carried on by the Taxpayer did not exceed the threshold period provided under the DTAA
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Income Tax
Consideration received under a composite contract for services which are ancillary to the main objective of providing a software user license held to be in the nature of Royalty
Income Tax
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Liaison Office (LO) involved merely in purchasing activity is not a Permanent Establishment (PE)
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Withholding tax not required on payment to non-resident agents of artists in absence of a permanent establishment
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Payments for reassembling and recommissioning of machinery not taxable
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Mere provision of a dredger on dry lease for carrying out dredging activity in India does not result in the taxpayer having a PE as per the India-Neth
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Income from supply of information relating to various markets should be taxed as business profits under the India-Singapore tax treaty
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Income Tax
