#permanent establishment
Log in to FollowEvery article filed under the “permanent establishment” tag — analysis, news and updates.
212 articlesGoods and Services Tax
Goods and Services Tax
GST and Income Tax on Software Purchases from Foreign Vendors Without PE in India
Income Tax
Income Tax
Lease income held as business profit, not royalty under India–Ireland DTAA without PE
Income Tax
Income Tax
SC Expands Fixed Place PE: Effective Control Over Physical Presence
Income Tax
Income Tax
No Office, No Expatriates, No PE: ITAT Delhi Rejects Revenue’s Repeated PE Allegation
Income Tax
Income Tax
Hyatt PE Case: SC Upholds ‘Disposal Test’ under India-UAE DTAA
Income Tax
Income Tax
No Fixed Place, Service PE or DAPE: ITAT Delhi Holds No PE in India, Profit Attribution Quashed
Income Tax
Income Tax
Disposal Test or Disposal Trap? How Hyatt Turned Oversight into Permanent Establishment
Income Tax
Income Tax
No Section 40(a)(i) Disallowance for Purchases from Foreign AEs without PE in India: Delhi HC
Income Tax
Income Tax
ITAT Mumbai Cuts Through the Rough: No Attribution Without PE
Income Tax
Income Tax
No PE in India for Irish Aircraft Lessor – Lease Rentals Taxable Only in Ireland under DTAA
Income Tax
Income Tax
Functional control over core Indian operations constitutes a Fixed Place PE: SC
Income Tax
Income Tax
SC: Substance over Form-Hyatt Ruling Strengthens India’s PE Jurisprudence
Income Tax
Income Tax
Hyatt International’s India Operations Held Taxable: SC Clarifies Scope of PE
Income Tax
Income Tax
