Taxpayer wins ruling on dependent agents in India
August 28, 2008
The Bombay High Court has ruled that payment of arm’s length remuneration to a Dependent Agent Permanent Establishment (DAPE) in India extinguishes the tax liability of the foreign enterprise
In a reversal of the Income Tax Appellate Tribunal’s (ITAT) decision, the High Court held that where a Dependent Agent (DA) is remunerated on an arm’s-length basis by the foreign enterprise, no further profits can be attributed to the DAPE.
The rest of this article is available to subscribers and active trialists* only.
Subscribe today for full access to this article.
Alternatively take a free trial, giving you access for one week*.
If you are already a subscriber, please log in below to access the rest of this article.
*some articles may be excluded from free trialists.