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Direct Tax

India’s pillar two pledge may have limited impact, experts warn

With corporate tax rates already exceeding 15%, India will need to think creatively to extract additional revenue through new pillar two rules, local partners tell ITR

Tom Baker, July 22 2024

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India: Delhi’s High Court maintains that overseas GE entities have a PE in India

Delhi High Court (HC) has confirmed the Income Tax Appellate Tribunal's decision that various overseas entities of the GE Group had a fixed place, permanent establishment (PE), and a dependent agent PE in India.

Rakesh Dharawat, January 28 2019
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Indian tax treaty benefits available without providing a tax residency certificate

The Income-tax Act, 1961 was amended in 2012 such that non-resident taxpayers are not entitled to claim relief under a tax treaty unless they obtain a tax residency certificate (TRC) from their country of residence. But a recent court ruling has changed the situation.

Hariharan Gangadharan, October 15 2018
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Indian Authority for Advance Rulings rules on PE and income characterisation

Litigation in respect of when a non-resident has a permanent establishment (PE) in India has always been a contentious issue.

Rakesh Dharawat, August 24 2018

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