Rolls Royce decision : income attribution to permanent establishments

Journal
Kapoor, S.
International Transfer Pricing Journal 2008 (Volume 15), No. 3
PriceUSD 45

After describing the background of the recent judgment of the Income Tax Appellate Tribunal in the Rolls Royce case, this article presents the author's justification of his belief that the case was decided incorrectly. The case in question concerns the attribution of income to an Indian permanent establishment in an income tax treaty context.