Court springs PE debate back into life

October 19 2011

In two separate judgments Delhi High Court ruled on the tax liability of Rolls Royce and Rolls Royce Singapore due to their operations in India. Common issue in both the matters was exposure to a permanent establishment (PE) in India and quantum of profits to be attributed to operations carried out by the PE in India. Sunil Jain of J Sagar & Associates investigates.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

Topics

Feature India Quarterly November 2011-January 2012 (September 2011)

more across site & bottom lb ros

More from across our site

Direct Tax

US withdraws from UN global tax treaty negotiations

It is understood that the US has vowed to oppose any outcome from talks taking place at the UN

Sam Sholli, February 04 2025

Direct Tax

RSM records double-digit tax revenue boost as turnover hits $10bn

It’s the second year in a row that RSM’s tax business has posted fee income growth above 10%

Tom Baker, February 04 2025

Direct Tax

India: Reassuring guidance on tax treaty entitlement for cross-border transactions

Recent guidance from the Indian tax authorities should provide confidence for investors, says Sanjay Sanghvi of Khaitan & Co

Sanjay Sanghvi, February 03 2025

Direct Tax

‘Considerable uncertainty’ over Trump’s pillar two memo: KPMG policy head

Grant Wardell-Johnson also suggests there could be solutions to the friction between the US and the OECD when it comes to pillar two

Sam Sholli, February 03 2025

Direct Tax

Trump prepares to impose 25% tariffs on Canada and Mexico

The president had so far avoided announcing tariffs on the US’s neighbours despite previous threats

Sam Sholli, January 31 2025

Direct Tax

This week in tax: A&M continues ‘big four’ recruitment drive in Europe

The firm brought in three managing directors from EY and Deloitte in Europe; in other news, KPMG’s bid to practise law in US was delayed

Sam Sholli, January 31 2025

Direct Tax

‘No benefits for taxpayers’: Advisers debate External Revenue Service

One expert argues the ERS would be unlikely to improve taxpayers’ experience unless it comes with additional funding to hire more agents and staff

Sam Sholli, January 30 2025

Transfer Pricing

2025 growth business. wooden block with 2024 change to 2025, Set up objective target business cost and budget planning for new year concept

Transfer pricing trends for 2025: looking back to look ahead

From pillar two and amount B to Apple’s headline EU Commission dispute, Martin Bonner and Yiwen Ping of Kreston Global argue that 2024’s key TP developments will inform 2025

Martin Bonner, January 30 2025

Direct Tax

ITR+ Talent Tracker Annual Review: Three firms share top spot amid US recruitment spree

Holland & Knight, Nelson Mullins and McCarter & English made the joint-most tax partner hires in the US last year, according to annual ITR Talent Tracker data

Sam Sholli, January 29 2025

Transfer Pricing

HMRC registers ‘significant’ £1.8bn TP yield for 2023/24

Despite a three-year-high in tax revenues generated from settling TP cases, HMRC reported a sharp fall in resolved MAP disputes

Sam Sholli, January 29 2025