In order to treat any agent as PE within meaning of Paras 4 and 5 of article 5 of relevant DTAA it is very vital that such agent should fit into description of ‘Dependent Agent’ and has to perform either of activities as mentioned in articles 5(4) and 5(5)
Varian India (P.) Ltd. v. Assistant Director of Income-tax (International Taxation), Range-2(1)
Trade tax paid in Germany
Background Recently, the Bombay High Court (High Court) in the case of Chiron Bearing Gmbh & Co. [1] (the taxpayer) held that the limited partnership is entitled to claim the benefit of India-Germany tax treaty (tax treaty) in respect to lower rate of tax on royalties and Fees for Technical […]
Interest paid on amount borrowed
Background Recently, the Ahmedabad Bench of the Income-tax Appellate Tribunal (the Tribunal) in the case of Adani Enterprises Ltd[1]. (the taxpayer) held that the interest payment by a resident to a non-resident in relation to the amounts borrowed for investment in overseas subsidiary neither accrues or arises nor deemed to […]
International Tax Services
In today’s world, the challenges as well as opportunities for clients stem from an effectively managed local and foreign tax planning that aligns with the overall business objectives. At Tennet tax & legal, we help our clients reduce their overall taxes and thereby enhancing margins and growth. Our services include […]