On 7 May 2014, the Indian Income Tax Appellate Tribunal issued its decision on whether or not the rendering of services by a U.K. company that are connected with their clients operations in India constitute a permanent establishment (PE) in India.
In the case, the Indian tax authorities held that the services provided by the U.K. company constituted a PE in India based on the U.K.-India tax treaty, and that the actual profits attributed to the PE should be subject to tax.
The U.K. company …