India: No PE under tax treaty with United States | KPMG | GLOBAL
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India: No permanent establishment under tax treaty with United States

India: No PE under tax treaty with United States

The KPMG member firm in India has prepared reports about the following tax developments (read more at the hyperlinks provided below).


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  • Permanent establishment (PE) under India-United States income tax treaty: The Supreme Court of India held that the outsourcing of work to India—a subsidiary of a U.S. company, providing back-office support services—does not constitute a fixed-place PE in India. The case is: E-Funds IT Solution Inc. Read an October 2017 report [PDF 647 KB]
  • Payment for distribution agreement: The Bangalore Bench of the Income-tax Appellate Tribunal held that the payment for distribution rights is taxable as royalty income under the provisions of the Income-tax Act, 1961 as well as under the India-Ireland income tax treaty. The case is: Google India Private Ltd. Read an October 2017 report [PDF 967 KB]

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