India's High Court of Allahabad recently ruled on whether the liaison office of the U.S company Brown & Sharp constituted a permanent establishment (PE) in India. Brown & Sharp used the liaison office to engage with customers purchasing products directly from the U.S. company. The following provides a summary of the case. During an audit, the Indian tax authorities determined that the liaison office constituted a PE because its activities were beyond acting as a communications channel and involved sales activities. As a result the tax authorities determined that the related receipts of the Brown & Sharp should be subject...