OrbitaxTreaty between India and United States – Indian decision that similar business activities do not give rise to a PE
|Treaty Development|India; United States
The Income Tax Appellate Tribunal (ITAT) delivered its decision on 26 July 2013 in the case of ITO v. Pubmatic India Pvt Ltd (ITA No. 7044/MUM./2011) that a subsidiary is not a permanent establishment (PE) of its overseas parent company merely because both companies cater to each other in carrying on a similar business.
(a) Facts. The Taxpayer (i.e. Pubmatic India Pvt. Ltd.), an Indian compa…
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