India - Case Note: Credit Card Payment Infrastructure and Network Constitutes a Permanent Establishment in India
- A. Dugar; L. Bhandari; D. (Dhruvi) Jain
- Asia-Pacific Tax Bulletin, 2019 (Volume 25), No 1
- 23 January 2019
This case note reviews the ruling issued by the Authority for Advance Rulings to MasterCard Asia Pacific Pte Ltd, which decided that MasterCard Asia Pacific’s use of the network and infrastructure for processing card payment transactions for customers in India constituted a fixed place permanent establishment, a services permanent establishment and a dependent agent permanent establishment of Mastercard Asia Pacific in India, under article 5 of the India-Singapore double tax treaty.