Seismic Survey Vessel Constitutes a Permanent Establishment

Journal
Author
Dugar, A.; Bhandari, L.
Country
India
Published Date
Issue
Asia-Pacific Tax Bulletin 2018 (Volume 24), No. 4
FormatPDF
EUR
45
| USD
50 (VAT excl.)

This case note reviews the ruling issued by the Authority for Advance Rulings to SeaBird Exploration FZ LLC, which determined that the applicant’s seismic survey activities conducted from its vessels operating in Indian territorial waters constituted a fixed place permanent establishment in India under article 5(1) of the India-United Arab Emirates Income Tax Treaty (1992).