The Resource Analysis of the Samsung case on the determination of a permanent establishment for services provided by seconded employees of a Korean parent to its subsidiary in India

Analysis of the Samsung case on the determination of a permanent establishment for services provided by seconded employees of a Korean parent to its subsidiary in India

Label
Analysis of the Samsung case on the determination of a permanent establishment for services provided by seconded employees of a Korean parent to its subsidiary in India
Title
Analysis of the Samsung case on the determination of a permanent establishment for services provided by seconded employees of a Korean parent to its subsidiary in India
Creator
Subject
Language
eng
Summary
This article examines the ruling of the Delhi Bench of the Income Tax Appellate Tribunal (ITAT or the Tribunal), i.e. the highest fact-finding authority under the Indian Income Tax Act (the Act), in the case of Samsung Electronics Co. Ltd. and the ramifications of that case for the interpretation of the treaty article on the determination of a permanent establishment, especially in the case of expatriate employees seconded and visiting the Indian subsidiary and the attribution of profits to a PE. The issue of reassessment proceedings under Indian law is also considered
Citation source
In: International transfer pricing journal. - Amsterdam. - Vol. 25 (2018), no. 5 ; p. 367-371
http://library.link/vocab/creatorName
  • Patel, V.T
  • Visharia, K.P
  • Mahajan, A. (Amol)
Geographic coverage
Asia
Language note
English
http://library.link/vocab/subjectName
  • transfer pricing
  • PE
  • secondment
  • fixed establishment
  • case law
Label
Analysis of the Samsung case on the determination of a permanent establishment for services provided by seconded employees of a Korean parent to its subsidiary in India
Instantiates
Publication
Label
Analysis of the Samsung case on the determination of a permanent establishment for services provided by seconded employees of a Korean parent to its subsidiary in India
Publication

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