Indo-French DTAA – Article 5 of India France DTAA states that ...

India-France DTAA: Computer Servers Define Permanent Establishment, Impacting Tax Obligations for Cross-Jurisdictional Operations.

February 16, 2012

Case Laws Income Tax AAR

Indo-French DTAA – Article 5 of India France DTAA states that even existence of a computer server amounts to existence of a PE within a jurisdiction...... - AAR

View Source

← Previous Next →

Indo-French DTAA – Article 5 of India France DTAA states that ...

India-France DTAA: Computer Servers Define Permanent Establishment, Impacting Tax Obligations for Cross-Jurisdictional Operations.

February 16, 2012

Case Laws Income Tax AAR

You may also like:

Taxability of interest on income tax refund received - PE in India or not? - whether shall be taxable as business income under Article 7 of India-France DTAA as against...

Taxability of Income in India - The receipt of IUC charges cannot be taxed as Royalty under Article 13 in India of India-France DTAA. The payment received by the...

Fees for technical services (FTS) - India France DTAA - claiming the benefit of the restricted definition under India USA DTAA - Since the assessee has been found not to...

TDS u/s 195 - Disallowance u/s 40(a)(i) - the said income in the hands of non-resident has to be considered in the light of the provisions of DTAA between India and the...

Permanent Establishment under Article 5 of the DTAA between India and U.S.A - Whether Appellant has a Permanent Establishment ('PE') in India under Article 5 of the DTAA...

TDS u/s 195 - Disallowance of sales commission paid to foreign agents - There is no dispute that these foreign agents do not have permanent establishment in India and...

PE in India - India-Spain DTAA - business profit carried out through PE - Services rendered from outside India - there is no Permanent Establishments during the relevant...

Income accrued in India - Permanent Establishment (PE) - the distribution income earned by the assessee cannot be taxed in India because Taj India does not constitute an...

Clubbing of income of Non-resident and Permanent Establishment (PE) - Levy of surcharge at 5% as against assessee’s claim of 2% - The royalty and Fee for Technical...

Withholding Tax u/s 195 - CIT(A) examined the taxability of the non-resident under the provisions of the DTAA between India and Italy. The AO, in the Remand Report, had...

Payment received from resellers in India for acquisition of computer software - Assessee who is a non resident does not have a permanent establishment and therefore...

Permanent Establishment in India - advertisement revenue - India-Mauritius DTAA - foreign company / Non-resident - Taj India cannot be held to be a DAPE of the assessee...

Income accrued in India - royalty receipts - transfer of copyright in the software - India-UK DTAA - The Impugned Rulings passed by the learned AAR are set aside and it...

Existence of Fixed Place Permanent Establishment (“Fixed Place PE”) and Supervisory Permanent Establishment (“Supervisory PE”) - India-Japan DTAA - Merely providing...

Income accrued in India - permanent establishment (PE) - Withholding of tax in India - vessel engaged in seismic survey at high sea - The sum paid by the applicant to...

Quick Updates: