In a judgment issued on 24 July 2025, India's Supreme Court found that Hyatt International Southwest Asia Ltd. (Hyatt) has a fixed place permanent establishment (PE) in India under Article 5(1) of the India-UAE tax treaty due to its enforceable operational control over hotel functions, and the company is therefore liable to tax on profits attributed to that PE. Hyatt, a UAE tax resident, entered into a 20-year Strategic Oversight Services Agreement (SOSA) with Indian hotel owners to provide …