P.E. in India - SIPL was an independent agent under Article ...

SIPL is an independent agent under Article 5(6) of the India-Holland tax treaty; no Permanent Establishment in India.

August 24, 2017

Case Laws Income Tax AT

P.E. in India - SIPL was an independent agent under Article 5(6)of the tax treaty between India and Holland, that the activities of the agent were carried out in its ordinary course of business, that the agent was not wholly and exclusively devoted to the assessee, that payments made to SIPL were at arm's length - Assessee does not have PE in India

View Source

← Previous Next →

P.E. in India - SIPL was an independent agent under Article ...

SIPL is an independent agent under Article 5(6) of the India-Holland tax treaty; no Permanent Establishment in India.

August 24, 2017

Case Laws Income Tax AT

You may also like:

Income accrued in India - Permanent Establishment (PE) in India under Article–5 of the India–Mauritius Tax Treaty - The two companies were not exclusively working for...

The HC held that the Liaison Office (LO) of the US company engaged in Money Transfer Services did not constitute a Permanent Establishment (PE) in India under the...

Short term capital gain - sale of units of mutual funds - Article 13(4)/13(5) of DTAA of India-UAE - the gains arising from transfer of units of mutual funds should not...

ITAT held that rights entitlement constitutes a distinct asset from shares under the India-Ireland DTAA, similar to derivatives. While shares fall under Article 13(5) of...

TDS u/s 195 - Disallowance of sales commission paid to foreign agents - There is no dispute that these foreign agents do not have permanent establishment in India and...

Income accrued in India - PE in India - computers installed at the premises of the subscriber constitute a PE of the assessee in India in terms of Article 5 (1) of...

Permanent Establishment (PE) in India - attribution of profit to the PE - Revenue authorities have not brought any material on record to demonstrate that the activities...

ITAT adjudicated a tax dispute involving consultancy income from a non-resident entity without permanent establishment (PE) in India. The tribunal examined treaty...

Income accrued in India - For the purpose of applying Article 13(5) of the India-Belgium tax treaty two fold conditions are required to be cumulatively satisfied viz....

AO's addition of "washout charges" as income was rejected. ITAT held that washout charges are business income, not speculative income. Even if speculative, it would be...

Permanent Establishment - Car is manufactured by the Audi AG outside India and constitutes a separate and independent activity. As noted earlier the car is sold to VW...

Assessee employed by Indian entity but sent on long-term international assignment to Singapore. Salary received in India for administrative reasons, but employment...

Income taxable in India - PE in India - Once we hold that in the light of the present legal position, existence of dependent agency permanent establishment in wholly tax...

Permanent Establishment under Article 5 of the DTAA between India and U.S.A - Whether Appellant has a Permanent Establishment ('PE') in India under Article 5 of the DTAA...

Taxability of income - Characterization of receipts - software sub-licence fee - the income in dispute, since can be classified under other Articles of the tax treaty,...

Quick Updates: