Service Permanent Establishment-Changing Landscape – Suraj Nangia

Recently, the Tribunal, had made interesting observation in case of ABB-FZ [2017] 83 Taxmann 86 (Bengaluru – Trib) while interpreting provisions of service PE.  It held that for constituting a Service PE it is not the stay of employees for the specified period which is required to be met but continuous rendition of services by the foreign company. Suraj Nangia, Partner with inputs from Mansi Chopra, Manager, Nangia & Co LLP contributed…

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Multilateral Instrument- Changing Landscape of Cross Border Transactions

Way back in 90s, globalisation and opening-up of the economy changed the manner in which the businesses were conducted. With passage of time, businesses environment became more uncertain and thus dynamic. Multinational Corporations (‘MNCs’) devised strategies to efficiencies in their tax bill as well. However, loss of revenue led to the convergence of the governments worldwide to bring turnaround changes in the taxation laws. One such measure is the Multilateral…

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