Permanent establishment threshold period under India-Cyprus income tax treaty

By | August 9, 2018
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(Last Updated On: August 21, 2018)

Permanent establishment threshold period under India-Cyprus income tax treaty:

The Delhi Bench of the Income-tax Appellate Tribunal held that the taxpayer did not constitute an installation permanent establishment (PE) under Article 5(2)(g) of the India-Cyprus income tax treaty given the 12-month threshold period was not met. The tribunal observed that preparatory work relating to a contract cannot be counted on calculating the threshold period. The case is: Bellsea Ltd.

Read an August 2018 report [PDF 562 KB] of KPMG

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