Indian subsidiary of Dutch holding company not “ permanent establishment ” in India

By | February 17, 2017
(Last Updated On: February 17, 2017)

Indian subsidiary of Dutch holding company not “ permanent establishment ” in India

 The Delhi Bench of the Income-tax Appellate Tribunal held that an Indian subsidiary of the taxpayer—a Dutch group holding company, engaged in selling storage system equipment and products (including embedded software) and rendering certain services in India—is not a permanent establishment under provisions of the India-Netherlands income tax treaty. There was no evidence that the taxpayer had personnel in India or that it controlled the Indian subsidiary. The case is: NetApp B. V. Read a February 2017 report [PDF 350 KB] of KPMG

Leave a Reply

Your email address will not be published.