Recent Blog Articles


Were the Formula One cases relevant for the Indian AAR's ruling in MasterCard?
This article analyzes as to how the Delhi High Court's and the Indian Supreme Court's decisions in Formula One were distinguishable in the Indian AAR's ruling in MasterCard...Read more

‘Duration test’ for permanent establishment: Two interesting cases where 6-month time threshold was applied
This article analyses two interesting cases wherein 6-month threshold was upheld for the duration test, a prerequisite for existence of a fixed place permanent establishment. ..Read more

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Recent Presentations


Important Danish Supreme Court's Decision on Income Characterization: Business Income versus Income from Immovable Property.
 This presentation covers an important Danish Supreme Court's decision on Income Characterization...Read more

German Federal Tax Court's decision: Place used to provide service amounts to fixed place PE.
 This presentation covers an interesting German court's decision...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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