Del. HC: Company’s Subsidiary Doesn’t Ipso Facto Constitute its Permanent Establishment - (27 Feb 2025)
DIRECT TAXATION
Del. HC has held that there is no general presumption in law that a subsidiary can never be acknowledged to be a Permanent Establishment (PE). This is since Article 5(8) of India-Finland Double Taxation Treaty itself merely states that the said factor alone shall not be determinative of PE question.
Tags : DELHI HIGH COURT PERMANENT ESTABLISHMENT DOUBLE TAXATION TREATY
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