The GE and Formula One Cases

Journal
Sharma, S. (Sanjeev)
India
Asia-Pacific Tax Bulletin 2019 (Volume 25), No. 4
PriceUSD 45

This article considers two recent judgments. The Supreme Court in the case of Formula One World Championship Limited held that the permanency of a fixed place through which a non-resident carries on business can be relative and depends on the nature of the business. In a decision involving the General Electric Group, the Delhi High Court opined on agency PE and the exclusionary rule on the ground of auxiliary and preparatory activities for fixed place PE.