Permanent establishment rules determine when cross border business presence creates taxable nexus under the Greece-India tax treaty. The treaty defines key concepts for tax allocation: territorial scope, 'person' and 'company' as taxable units, residency criteria based on incorporation or place of management and control, and 'enterprise' as industrial or commercial undertakings. The permanent establishment rule treats a fixed place of business or specific projects as creating taxable presence, excludes mere storage and limited purchasing activity, and sets agency-based deeming conditions while excluding independent brokers and mere subsidiary relationships. Pension, annuity and competent authority are separately defined, and undefined treaty terms defer to domestic tax law.
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 determine when cross border business presence creates taxable nexus under the Greece-India tax treaty.
The treaty defines key concepts for tax allocation: territorial scope, "person" and "company" as taxable units, residency criteria based on incorporation or place of management and control, and "enterprise" as industrial or commercial undertakings. The permanent establishment rule treats a fixed place of business or specific projects as creating taxable presence, excludes mere storage and limited purchasing activity, and sets agency-based deeming conditions while excluding independent brokers and mere subsidiary relationships. Pension, annuity and competent authority are separately defined, and undefined treaty terms defer to domestic tax law.
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