Del. HC: Company’s Subsidiary Doesn’t Ipso Facto Constitute its Permanent Establishment - 27.02.2025

Del. HC has held that there is no general presumption in law that a subsidiary can never be acknowledged to be a Permanent Establishment (PE). This is since Article 5(8) of India-Finland Double Taxation Treaty itself merely states that the said factor alone shall not be determinative of PE question.

Tags : Delhi High Court Permanent Establishment Double Taxation Treaty

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