https://www.taxtmi.com/caselaws?id=361791 The ruling determined that the Applicant has a Permanent Establishment (PE) in India under Article 5 of the India-Singapore DTAA. The MasterCard Interface Processors (MIPs) in India, along with other elements of the MasterCard Network, create fixed place PEs due to significant functions performed. The Indian subsidiary and Bank of India's premises also constitute PEs. Arm's length remuneration to the Indian subsidiary does not absolve further attribution of global profits. A portion of fees received from Indian customers is classified as royalty and taxed under Article 7 of the DTAA. The Applicant is required to withhold tax at source on the amount attributed to the PE in India. en-us Wed, 06 Jun 2018 00:00:00 +0530 Thu, 16 Aug 2018 17:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=361791 The ruling determined that the Applicant has a Permanent Establishment (PE) in India under Article 5 of the India-Singapore DTAA. The MasterCard Interface Processors (MIPs) in India, along with other elements of the MasterCard Network, create fixed place PEs due to significant functions performed. The Indian subsidiary and Bank of India's premises also constitute PEs. Arm's length remuneration to the Indian subsidiary does not absolve further attribution of global profits. A portion of fees received from Indian customers is classified as royalty and taxed under Article 7 of the DTAA. The Applicant is required to withhold tax at source on the amount attributed to the PE in India. Case-Laws Income Tax Wed, 06 Jun 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=361791