Seismic Survey Vessel Constitutes a Permanent Establishment

Journal
Dugar, A.; Bhandari, L.
India
Asia-Pacific Tax Bulletin 2018 (Volume 24), No. 4
PriceUSD 45

This case note reviews the ruling issued by the Authority for Advance Rulings to SeaBird Exploration FZ LLC, which determined that the applicant’s seismic survey activities conducted from its vessels operating in Indian territorial waters constituted a fixed place permanent establishment in India under article 5(1) of the India-United Arab Emirates Income Tax Treaty (1992).