Permanent establishment rules restrict agent-triggered PE, protect head office deductions, and treat container income as shipping profits. The Protocol clarifies that no special rule deems an insurance enterprise to have a permanent establishment merely by collecting premiums through a dependent agent; income from corporate rights granting enjoyment of immovable property may be taxed where the property is situated; deductions for head-office expenses must be no less than under the Indian Income-tax Act at entry into force and specified intercompany charges to the head office are non-deductible (with a banking exception for interest); and profits from international shipping or air operations include container-related income and interest integral to those operations.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Permanent establishment rules restrict agent-triggered PE, protect head office deductions, and treat container income as shipping profits.
The Protocol clarifies that no special rule deems an insurance enterprise to have a permanent establishment merely by collecting premiums through a dependent agent; income from corporate rights granting enjoyment of immovable property may be taxed where the property is situated; deductions for head-office expenses must be no less than under the Indian Income-tax Act at entry into force and specified intercompany charges to the head office are non-deductible (with a banking exception for interest); and profits from international shipping or air operations include container-related income and interest integral to those operations.
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