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India Court Holds Liaison Office does not Constitute PE under Tax Treaty with Japan

|Treaty Development|India-Japan
India-Japan

The Delhi High Court recently issued a decision on whether or not a liaison office (LO) in India may constitute a permanent establishment under the 1989 India-Japan tax treaty. The case involved Japan-based Mitsui & Co. Ltd., which had engaged in two power projects in India. In addition, Mitsui maintained an LO in India as permitted by the Reserve Bank of India (RBI) to carry on liaison act…

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