OrbitaxIndian Income Tax Appellate Tribunal Holds Liaison Office Constitutes a PE for Singapore Company and the TNMM Method Must be Applied to Attribute Profits
|Treaty Development|India-Singapore
A 17 September 2019 decision of the Delhi Income Tax Appellate Tribunal has been published concerning the treatment of a liaison office as a permanent establishment.
The case involved Hitachi High Technologies Singapore Pte Ltd (HHT Singapore), which established a liaison office (LO) in India for rendering preparatory and auxiliary services, including market research and liaison activities. I…
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