Tax alert: Each project site is separate fordetermining installation, supervisory PE has been saved
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Tax alert: Each project site is separate fordetermining installation, supervisory PE
12 October 2023
The Delhi Bench of the Income-tax Appellate Tribunal has held that, for determining installation or supervisory permanent establishment (PE) status, under Article 5(3) and Article 5(4) of the India-Singapore tax treaty, each project site will be considered as a separate project. The taxpayer did not have a PE in India as each project sitedid not exceed the threshold limit of 183 days.
