Ruling that domestic subsidiary of US company constitutes a permanent establishment

Journal
Author
Fazelbhoy, A.; Petiwalla, F.
Country
India; United States
Published Date
Issue
International Transfer Pricing Journal 2007 (Volume 14), No. 1
FormatPDF
EUR
45
| USD
50 (VAT excl.)

This article looks into the recent landmark decision in the Morgan Stanley and Co., US case, as an attempt to ratify the position that the Indian tax authorities have taken thus far regarding what does and what does not qualify as a permanent establishment in India.