Motor Racing Circuit Constitutes a Permanent Establishment

Journal
Dugar, A.
India
Asia-Pacific Tax Bulletin 2017 (Volume 23), No. 3
FormatPDF
USD
45

This case note explains the Delhi High Court’s November 2016 decision in Formula One World Championship Ltd v. Commissioner of Income Tax that the Formula One circuit in India constituted a fixed place of business and, consequently, a permanent establishment, although it was not used for a long period of time. The income derived therefrom was business income, which was subject to withholding tax in India.