The Resource Indian court rules secondment gives rise to FTS and service PE

Indian court rules secondment gives rise to FTS and service PE

Label
Indian court rules secondment gives rise to FTS and service PE
Title
Indian court rules secondment gives rise to FTS and service PE
Creator
Subject
Language
eng
Summary
The Delhi High Court has given a controversial ruling which seems to suggest that reimbursement of salaries for seconded employees qualify as FTS (fees for technical services) and hold that a service PE existed in the circumstances, despite India's treaties with the UK and Canada specifically excluding activities regarding such payments from those that can create a service PE
Citation source
In: Tax planning international review. - London. - Vol. 41 (2014),
http://library.link/vocab/creatorName
  • Srinivasan, R
  • Ghose, T
Geographic coverage
Asia
Language note
English
http://library.link/vocab/subjectName
  • secondment
  • services PE
  • technical services
  • tax treaty
  • advance tax ruling
  • case law
Label
Indian court rules secondment gives rise to FTS and service PE
Instantiates
Publication
Label
Indian court rules secondment gives rise to FTS and service PE
Publication

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