PE case law
India: Offshore services connected to Indian PE are exempt from tax under India-German tax treaty
On 3 April 2023, the Delhi Tribunal decided case TS-185-ITAT-2023(DEL), involving a German entity that provided airport management services in India. The entity had established a project office in India, which qualified as a permanent establishment (PE) in the country. The entity also provided offshore consultancy services from Germany. The German entity claimed that these services were no…