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India Supreme Court Holds Contract Service Provider Does Not Constitute PE under India-U.S. Tax Treaty

|Treaty Development|India-United States
India-United States

The Indian Supreme Court has issued its decision on whether two U.S. companies had a permanent establishment (PE) in India as a result of contract services outsourced to a related Indian company. The case involved U.S.-based e-Funds Corporation and its affiliate e-Funds IT Solutions Group Inc. (together e-Funds U.S.), which are engaged in the business of ATM management services, electronic paym…

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