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Treaty between India and UK – Indian decision on ascertainment of "business connection"/PE and attribution of profits

|Treaty Development|India-United Kingdom
India-United Kingdom

The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) delivered a ruling dated 26 October 2007 in the case of Rolls Royce Plc v. Deputy Director of Income Tax (ITA Nos. 1496 to 1501/DEL of 2007) on whether activities carried out via an agent resulted in a permanent establishment (PE) under the India-UK tax treaty (the Tax Treaty) and if so, how much of the profits could be at…

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