Recent Blog Articles


The Nokia Case: Could mere performance guarantee for a subsidiary’s installation activities give rise to a parent company’s permanent establishment?
This article analyzes the Indian ITAT's landmark decision on the issue as to whether issuance of a performance guarantee in respect of the subsidiary's quality of the installation activities could give rise to the parent company's permanent establishment in the source state...Read more

Permanent Establishment: The Indian tax authorities' application of the Formula One decision rejected
This article discusses a recent judicial precedent, wherein the Indian tax authorities' attempt to apply the landmark Formula One decision was rejected...Read more

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Recent Presentations


Transfer Pricing: TNMM And Adjustments For Depreciation Differences
How should the depreciation differences in case of the tested party and the comparables be treated under the TNMM? This presentation covers an interesting judicial precedent...Read more

Could software installation activities give rise to an ‘installation PE’?
This presentation covers an important judicial precedent, which examined as to whether software installation activities could give rise to an ‘installation PE’ under a tax treaty...Read more

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COMMENTARY


  • Article 5 of Tax Treaties
      (Permanent Establishment)
  • Article 7 of Tax Treaties
      (Business Profits)
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