Attributing Income to a Former PE and Other Issues: A Critical Comment on the SIS Live Case and on Judicial Propriety

Journal
Janssen-Sanghavi, D.; Bhatt, R.
India; International; OECD; United Kingdom
Bulletin for International Taxation 2023 (Volume 77), No. 10
Price USD 45

The authors analyse critically the approach adopted by the Indian Income Tax Appellate Tribunal whilst applying the India-UK Tax Treaty (1993) in the recent case of SIS Live (2023). They address important questions about the existence of, and timing issues in attributing income to, permanent establishments, and about judicial propriety.