The Resource Deputy Commissioner of Income Tax, Special Range-26 v Roxon OY : [2006] 10 SOT 454 (Mum)

Deputy Commissioner of Income Tax, Special Range-26 v Roxon OY : [2006] 10 SOT 454 (Mum)

Label
Deputy Commissioner of Income Tax, Special Range-26 v Roxon OY : [2006] 10 SOT 454 (Mum)
Title
Deputy Commissioner of Income Tax, Special Range-26 v Roxon OY : [2006] 10 SOT 454 (Mum)
Contributor
Subject
Language
eng
Summary
Judgment by the Income Tax Appellate Tribunal (ITAT) dated 18 August 2006. In the case the 'force of attraction' principle is discussed, which may apply where a non-resident has a permanent establishment (PE) in a country and also carries on trade with that country directly (and not through the auspices of the PE). In this case, a Finnish company had a PE in India, but also separately supplied equipment directly. The ITAT concluded that the profits from the supply of the equipment were not taxable in India through the PE situated there
Citation source
In: International tax law reports. - London. - Vol. 9 (2007),
Language note
English
http://library.link/vocab/relatedWorkOrContributorName
Baker, P
http://library.link/vocab/subjectName
  • case law
  • double taxation
  • tax treaty
  • PE
  • force of attraction
  • UN Model
Label
Deputy Commissioner of Income Tax, Special Range-26 v Roxon OY : [2006] 10 SOT 454 (Mum)
Instantiates
Publication
Label
Deputy Commissioner of Income Tax, Special Range-26 v Roxon OY : [2006] 10 SOT 454 (Mum)
Publication

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