The Calcutta High Court issued a judgment on 22 May 2024 concerning the application of the higher tax rate for foreign companies on the profits of a bank branch that constituted a permanent establishment (PE) in India. The case involved a branch of ABN Amro Bank NV (now the Royal Bank of Scotland NV), which is registered as a scheduled bank in India. The branch constitutes a PE in India and, as per Article 7 of the 1988 India-Netherlands tax treaty, where a foreign enterprise carries on busin…