PE case lawIndia: High Court clarifies PE status for a company providing money transfer servicesOn 18 December 2024, the Delhi High Court ruled on a case addressing the determination of a Permanent Establishment (PE) under the India-United States tax treaty. The case involved a foreign company that facilitated money transfer services through a network of agents in India, raising questions about whether these arrangements constituted a PE in India.The tax authorities contended that the company had both a fixed place of business and a Dependent Agent PE in India. They argued that the company's liaison office functioned as a fixed...