Monthly Archives: July 2014

  • Can Supervisory Activities/work constitute a Permanent Establishment (PE) of the Multinational Enterprise ??

    July 2 2014

    n a large construction/assembly project awarded to an Indian arm of foreign parent, it is common practice that the technicians of the foreign parent visit the host country on a frequent basis to supervise the overall work and provide the necessary technical guidance to the management/employees of the Indian arm.

    Another set of transaction could be that a large construction/ assembly project is awarded to an Indian entity, however for better technical qualities, foreign companies expert in this filed, send their technicians to supervise the overall project work.

    Whether such Supervisory Services by foreign companies to Indian entities could result in a Supervisory PE of the foreign company and liable to higher rate of taxation in India ???

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