India's High Court recently ruled on the determination of a permanent establishment (PE) in India due to an installation or structure for exploration or exploitation in the country. The case was in regard to the tax treaty between India and the U.S., which includes provisions for a PE when an installation or structure is used for the exploration or exploitation of natural resources in India for a period of more than 120 days in any 12-month period. In the case at hand, the Indian tax authorities held that rigs brought into India for the purpose of oil and gas exploration...