Tax alert: Preparatory, auxiliary activities by LO, installation of software at agent premises, not PE has been saved
Article
Tax alert: Preparatory, auxiliary activities by LO, installation of software at agent premises, not PE
15 January 2025
The Delhi High Court, based on facts of the case, has held that the liaison office (LO) of the taxpayer in India neither constituted a fixed place permanent establishment (PE) nor a dependent agent PE in terms of Article 5 of the India-USA tax treaty. Further, the installation of software at Indian agents premises did not result in creation of PE in India.