Indian Tribunal Holds Time Spent on Projects may Not be Aggregated for PE Purposes Unless Specifically Provided for in Tax Treaty
The Mumbai Income Tax Appellate Tribunal has recently issued its decision on whether time spent on separate projects may be aggregated for the purpose of determining the existence of a permanent establishment under the India-Mauritius tax treaty. The case involved a Mauritius-based company that was engaged in installation and construction work for offshore oil exploration platforms. The company…
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