Case Note: Subsidiary of Foreign Parent Not Permanent Establishment in India

Journal
Dugar, A.; Bhandari, L.
India
Asia-Pacific Tax Bulletin 2018 (Volume 24), No. 5
FormatPDF
EUR
40
| USD
45
(VAT excl.)

In this case note, the authors outline the ruling by the Authority for Advance Rulings in Saudi Arabian Oil Company, which determined that an Indian subsidiary of a Saudi Arabian company did not constitute a permanent establishment in India under article 5 of the India-Saudi Arabia Income Tax Treaty (2006) where the Indian subsidiary merely provides business and marketing support services to its Saudi Arabian parent company.