A 21 December 2018 decision of the Delhi High Court was recently published concerning whether the role played by employees in India in relation to the negotiation of sales contracts was sufficient to constitute a permanent establishment under the provisions of the 1989 tax treaty with the United States. The case involved U.S.-based companies of the GE group (GE Overseas) and their sales operations in India, which included a liaison office meant only to provided limited market support services and certain expatriate employees working in India to support various GE businesses (GE India). The liaison office was remunerated on a...