UK vs Royal Bank of Canada: International Tax Case
This case examines whether payments received by the Royal Bank of Canada (RBC) under an oil exploration agreement were subject to UK taxation. The cor…
Tag: Permanent Establishment
India vs Samsung Electronics: Permanent Establishment Dispute
The High Court of Delhi ruled on appeals filed by the Commissioner of Income Tax (International Taxation) against Samsung Electronics Co. Ltd., challe…
Q&A: Avoiding Double Taxation on Cross-Border Advisory Fees – An African Example
QUESTION: If Company A is busy with a project (for example, in South Africa) and gets Company B based in Zimbabwe to do advisory work, company A will …
Permanent Establishments and Managing International Tax Risks: Insights from Key Cases
The concept of a Permanent Establishment (PE) is central to international taxation and transfer pricing. When multinational enterprises (MNEs) conduct…
Hyatt International vs. India (ADIT)
Hyatt vs India (ADIT) tackles several pivotal issues regarding the attribution of income to a Permanent Establishment (PE) in India, even in cases whe…
What is a Permanent Establishment, and How is Its Significance in Transfer Pricing?
A Permanent Establishment (PE) refers to a fixed place of business through which a foreign enterprise conducts business in another country. In the con…
Boston Scientific v. CIT (India): Permanent Establishment and TP Implications
This case, heard by the Indian courts, raises significant issues concerning the activities that constitute a PE, especially in relation to multination…
Nokia vs. India: Permanent Establishment and Profit Attribution Dispute
The case revolved around whether Nokia Solutions and Networks Oy had a Permanent Establishment (PE) in India, and whether profits could be attributed …
UPS Asia Group Pte. Ltd. Case: Transfer Pricing and Permanent EstablishmentUPS Asia Group Pte. Ltd. Case:
The case of UPS Asia Group Pte. Ltd. vs. Asstt. Commissioner of Income Tax revolves around the interpretation of whether the applicant had a "Business…
Anwar & Co. v. CIT: Understanding Permanent Establishment in International Taxation
The case of Anwar & Co. v. CIT is a landmark ruling by the Supreme Court of India that delves deep into Permanent Establishment (PE) and its implicati…