https://www.taxtmi.com/caselaws?id=361729 The Supreme Court held that the business support/marketing activities proposed by Aramco India do not create a Permanent Establishment (PE) for Saudi Aramco in India under the Double Taxation Avoidance Agreement. Aramco India's premises are not at the disposal of Saudi Aramco for its main business activities, and the services provided do not constitute a Fixed Place PE, Service PE, or Agency PE. The separate legal entity status of Aramco India and the nature of support services were key factors in the ruling. The decision is contingent on the accurate compensation of activities in compliance with transfer pricing laws. en-us Thu, 31 May 2018 00:00:00 +0530 Thu, 19 Jul 2018 16:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=361729 The Supreme Court held that the business support/marketing activities proposed by Aramco India do not create a Permanent Establishment (PE) for Saudi Aramco in India under the Double Taxation Avoidance Agreement. Aramco India's premises are not at the disposal of Saudi Aramco for its main business activities, and the services provided do not constitute a Fixed Place PE, Service PE, or Agency PE. The separate legal entity status of Aramco India and the nature of support services were key factors in the ruling. The decision is contingent on the accurate compensation of activities in compliance with transfer pricing laws. Case-Laws Income Tax Thu, 31 May 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=361729