PE case law
Indian Court examines subsidiary's role in determining the existence of a PE
On 28 May 2024, the High Court of Delhi issued a decision that analyzed whether a nonresident had a Permanent Establishment (PE) in India under the United States (US)-India tax treaty. In this case, the nonresident is a US-based company engaged in providing solutions and technologies to rail customers across the globe. The nonresident has a wholly owned subsidiary in India that provides back-office and technic…