Tag Archives: permanent establishment

Race car circuit constitutes “fixed place PE” under India-United Kingdom income tax treaty:

Race car circuit constitutes “fixed place PE” under the India-United Kingdom income tax treaty: The Supreme Court of India held that an international circuit constitutes fixed place of business under the India-UK income tax treaty, since the circuit was under the control and at the disposal of the taxpayer. The case is: Formula One World… Read More »

Liaison office of overseas taxpayer is permanent establishment (PE) in India

The Delhi Bench of the Income-tax Appellate Tribunal held that the liaison office of an overseas taxpayer group constitutes a fixed place permanent establishment (PE) in India under the provisions of the India-United States income tax treaty. The tribunal noted that the activities conducted by the company, from the liaison office premises, were substantial and… Read More »

No disallowance of section 40(a)(i) if Non resident has no permanent establishment in India

Issue The assessee is supplying software related services and in this connection has made payment of communication charges, commission charges, legal and professional charges, marketing & selling charges and business development charges. These payments were made to various entities abroad and some of which are associated concerns of the assessee company. It was also noted… Read More »