Tax alert: PE construed from day oil rigenters Indian territory, initial repair/upgrade days in India considered

13 October 2023

The Bombay High Court, based on facts, has held that the date on which the rig (for drilling operations) entered India is the date on which the count of 183 days would begin for the purpose of determining permanent establishment [under Article 5(5) of the India-Singapore tax treaty], in connection with the exploration, exploitation, or extraction of mineral oil.

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