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Delhi HC Ruling on PE & Profit Attribution

Published on Tue, Sep 13,2011 | 18:14, Updated at Tue, Sep 13 at 18:18Source : 

This E&Y Tax Alerts summarizes two recent rulings of the Delhi High Court in the cases of Rolls Royce Plc and Rolls Royce Singapore on the issue of whether the foreign enterprises, based on the facts, constituted a permanent establishment (PE) in terms of Article 5 under India’s Double Taxation Avoidance Agreements with the UK and Singapore respectively and also with respect to the amount of profit attributable to such a PE.

For more details, please click on the attachment below...

Attachments : EY Tax Alert - Delhi HC rules on permanent establishment and profit attribution_Rolls Royce_ .pdf

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