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India: PE of global payment provider; Singapore tax treaty, relief provision

India: PE of global payment provider; tax treaty

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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  • Global payment solution provider company—PE in India: The Authority for Advance Rulings (AAR) found that a global payment solution provider company had a permanent establishment (PE) in India because the applicant (the regional headquarters for Asia Pacific, Africa, and Middle East) had a processor and network belonging to the corporate group that constituted a fixed-place PE under the India-Singapore income tax treaty. The AAR noted the applicant was conducting its business of facilitation of authorisation of the transaction through such processors and network, both at the disposal of the applicant. The case is: MasterCard Asia Pacific Pte. Ltd. Read a July 2018 report [PDF 578 KB]

  • Revised monetary limits, conditions for appeals by tax department: The Central Board of Direct Taxes issued a circular that revises the monetary limits and conditions for the filing of appeals by the tax department in tribunal, high court, or Supreme Court cases. Read a July 2018 report [PDF 659 KB]

  • “Limitation of relief” under India-Singapore income tax treaty: The Mumbai Bench of the Income-tax Appellate Tribunal held that the “limitation of relief” provisions under Article 24 of the India-Singapore income tax treaty do not apply to capital gain derived from the sale of shares, debt instruments, and derivatives of an Indian company that is taxable in Singapore under Article 13(4) of the tax treaty. The case is: D.B. International (Asia) Ltd. Read a July 2018 report [PDF 648 KB]

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