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PE Watch | Latest developments and trends, February 2025

|Tax Alerts, Legislation & Policy, Le ...|United States, India, Netherlands, Singa ...
United States, India, Netherlands, Singapore

PE case law

Indian court concludes that employees seconded to India do not constitute a permanent establishment

On 15 January 2025, the Delhi High Court ruled that the secondment of employees by a South Korean entity to its Indian subsidiary does not create a fixed place of business or a Service PE in India under the India-South Korea tax treaty. The Indian tax authorities had argued that the presen…

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