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 an article on Service Permanent Establishment-Changing Landscape for Corporate Professionals today- Taxmann.