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      • Blog
        Blog

        Subsidiary is Not a Permanent Establishment but Beware the ‘Virtual Projection’ Risk

        The Income Tax Appellate Tribunal, Delhi (ITAT) recently delivered a very significant decision in the case of Nokia Networks O.Y (Assessee)[1] on the issue of its permanent establishment (PE) in India...

        June 20, 2018
      • Blog
        Blog

        Taxing the Digital Economy: The Rule of ‘Significant Economic Presence’

        Taxation of international digital transactions has been a perplexing issue. As per the international tax rules, where an enterprise is a resident in one state with income originating in another state ...

        March 21, 2018
      • Blog
        Blog

        Outsourcing of Back Office Support Functions Does Not Create a Permanent Establishment

        Multinational enterprises often outsource back-office support operations to their captive subsidiaries in India. Additionally, foreign parent companies second their employees to provide guidance to th...

        January 12, 2018
      • Blog
        Blog

        Service PE Does Not Require Physical Presence of Employees

        Permanent Establishment (PE) is a significant feature of bilateral tax treaties and is a key threshold adopted by source countries to tax profits earned by non-resident entities from the business acti...

        October 26, 2017
      • Blog
        Blog

        Formula One: SC Lays Down the Formula for Permanent Establishment

        With globalisation spreading economic activities across jurisdictions, enterprises nowadays have a presence in several jurisdictions. The taxability of activities undertaken by companies on foreign so...

        June 6, 2017
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