The Resource Supreme Court rules on permanent establishment issues and attribution of profits in oursourcing industry

Supreme Court rules on permanent establishment issues and attribution of profits in oursourcing industry

Label
Supreme Court rules on permanent establishment issues and attribution of profits in oursourcing industry
Title
Supreme Court rules on permanent establishment issues and attribution of profits in oursourcing industry
Creator
Subject
Language
eng
Summary
In the recent landmark judgment of DIT (International Taxation), Mumbai v. Morgan Stanley and Co. delivered on 9 July 2007, the Supreme Court of India scrutinized the tax regime applicable to the outsourcing industry. The judgment deals with the circumstances when the permanent establishment of the non-resident entity comes into existence in India, the differences between stewardship and deputation and the issue of further attribution of profits to a permanent establishment beyond the arm's length price paid by the non-resident entity. This article analyses the background, reasoning and impact of the judgment and provides an overview of the treatment in India of issues relevant for the outsourcing industry
Citation source
In: Derivatives and financial instruments. - Amsterdam. - Vol. 9 (2007),
http://library.link/vocab/creatorName
  • Seth, M
  • Goradia, S
Geographic coverage
  • International
  • Asia
Language note
English
http://library.link/vocab/subjectName
  • case law
  • PE
  • allocation of profits
  • outsourcing
Label
Supreme Court rules on permanent establishment issues and attribution of profits in oursourcing industry
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Publication
Label
Supreme Court rules on permanent establishment issues and attribution of profits in oursourcing industry
Publication

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