Tax alert: SEBI Introduces key amendments to Related Party Transactions

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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.

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