Case Note: Subsidiary of Foreign Parent Not Permanent Establishment in India

Journal
Dugar, A.; Bhandari, L.
India
Asia-Pacific Tax Bulletin 2018 (Volume 24), No. 5
PriceUSD 45

In this case note, the authors outline the ruling by the Authority for Advance Rulings in Saudi Arabian Oil Company, which determined that an Indian subsidiary of a Saudi Arabian company did not constitute a permanent establishment in India under article 5 of the India-Saudi Arabia Income Tax Treaty (2006) where the Indian subsidiary merely provides business and marketing support services to its Saudi Arabian parent company.