Commentary : Morgan Stanley case answers the big question, but leaves others unanswered

Journal
Kapoor, S.
India; United States
International Transfer Pricing Journal 2007 (Volume 14), No. 6
FormatPDF
USD
45

After providing a summary of the Morgan Stanley case regarding the existence of permanent establishments in India, this commentary analyses tax issues which remain unresolved. These include the administration of tax filings; transfer pricing; the concept of permanence and its impact on separate establishments; and the application of the Court's ruling to dependent agent permanent establishments.