OrbitaxTreaty between India and Indonesia – Characterization of income from information supply for treaty purposes
|Treaty Development|India; Indonesia
The Income Tax Appellate Tribunal (ITAT) issued its decision on 16 January 2013 in the case of CIT v. P.T.Mckinsey Indonesia (ITA No. 7625/Mum/2010) that consideration for collating and supply of information would not be taxable under article 7 of the India-Indonesia tax treaty (the Treaty) in the absence of a permanent establishment (PE) in India.
(a) Facts. The Taxpayer (i.e. P. T. Mckinse…
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