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Supervisory services without having control of physical sites couldn’t constitute a PE as per DTAA with Germany

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  • Supervisory services without having control of physical sites couldn’t constitute a PE as per DTAA with Germany
Posted onon September 19, 2014

Tenet Tax Daily September 18 2014

By tenettax-team
Corporate Tax, International Tax

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Re-assessment affirmed as commission paid to foreign agent was included in cost of asset to escape TDS liability
Renouncing of right to purchase a property in lieu of a sum was ‘transfer’; to be taxed as capital gains

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