Attributing Income to a Former PE and Other Issues: A Critical Comment on the SIS Live Case and on Judicial Propriety
Journal
Country
India; International; OECD; United Kingdom
Published Date
Issue
Bulletin for International Taxation 2023 (Volume 77), No. 10
Document
The authors analyse critically the approach adopted by the Indian Income Tax Appellate Tribunal whilst applying the India-UK Tax Treaty (1993) in the recent case of SIS Live (2023). They address important questions about the existence of, and timing issues in attributing income to, permanent establishments, and about judicial propriety.