Supreme Court ruling on outsourcing industry opens debate on interpretation of permanent establishment issues

Journal
Patel, V.T.; Athavale, R.S.
India
International Transfer Pricing Journal 2008 (Volume 15), No. 2
FormatPDF
USD
50

This article examines the ruling of the Indian Supreme Court in 'Morgan Stanley' and the ramifications of that case for the interpretation of the treaty article on permanent establishments and the attribution of profit to a permanent establishment in an international context. Other Indian court cases that shed light on these issues are also considered.