https://www.taxtmi.com/caselaws?id=361382 Payments for global reservation services were held taxable in India as business profits attributable to a fixed place permanent establishment. The Authority applied the settled PE test and found that the integrated hotel arrangement placed the Indian hotel at the non-resident's disposal, with exclusive and effective control over core functions including staffing, marketing, pricing, purchasing, capital improvements, technical inputs and reservation services. Because the receipts were effectively connected with the permanent establishment, Article 12 was displaced by Article 7, and the separate royalty and fees for technical services characterisation was not examined further. en-us Thu, 24 May 2018 00:00:00 +0530 Fri, 22 Jun 2018 16:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=361382 Payments for global reservation services were held taxable in India as business profits attributable to a fixed place permanent establishment. The Authority applied the settled PE test and found that the integrated hotel arrangement placed the Indian hotel at the non-resident's disposal, with exclusive and effective control over core functions including staffing, marketing, pricing, purchasing, capital improvements, technical inputs and reservation services. Because the receipts were effectively connected with the permanent establishment, Article 12 was displaced by Article 7, and the separate royalty and fees for technical services characterisation was not examined further. Case-Laws Income Tax Thu, 24 May 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=361382