The Resource India : recent rulings on taxability of offshore supplies and services under a "turnkey contract"

India : recent rulings on taxability of offshore supplies and services under a "turnkey contract"

Label
India : recent rulings on taxability of offshore supplies and services under a "turnkey contract"
Title
India : recent rulings on taxability of offshore supplies and services under a "turnkey contract"
Creator
Subject
Language
eng
Summary
The taxability of income from offshore supplies and offshore services under a "turnkey contract" undertaken by a foreign company has always been a controversial subject in India. The Indian tax authorities have been taking a position that income from offshore supplies and offshore services is taxable in India. Recently, the Supreme Court in two rulings emphatically held that income from offshore supplies and offshore services are not taxable in India under the provisions of the Income Tax Act, 1961 or the Double Taxation Avoidance Agreements. This article analyses the principles concerning attribution of income to the Indian PE, including the Ishikawajma-Harima Heavy Industries and the Hyundai Heavy Industries cases
Citation source
In: Tax planning international review. - London. - Vol. 34 (2007),
http://library.link/vocab/creatorName
  • Kariya, J
  • Doshi, M
Geographic coverage
Asia
Language note
English
http://library.link/vocab/subjectName
  • allocation of income
  • PE
  • turnkey contract
  • case law
Label
India : recent rulings on taxability of offshore supplies and services under a "turnkey contract"
Instantiates
Publication
Label
India : recent rulings on taxability of offshore supplies and services under a "turnkey contract"
Publication

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