https://www.taxtmi.com/caselaws?id=301939 Reinsurance premium earned by a non-resident German reinsurer from Indian insurers was treated as not taxable in India because the contracts were concluded outside India and the Indian subsidiary and liaison office performed only preparatory or auxiliary functions. The subsidiary's support activities, including data collection, verification, market intelligence, administration, representation and training, were expressly restricted from contract conclusion, negotiation, final documentation or underwriting recommendations, so they did not create a business connection or a fixed place PE. The liaison office was limited to communication functions and could not engage in trading or reinsurance activity. The Revenue also failed to show authority in the subsidiary to conclude contracts or solicit business, so no dependent agent PE existed. en-us Fri, 14 Jun 2019 00:00:00 +0530 Wed, 27 Apr 2022 21:34:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=301939 Reinsurance premium earned by a non-resident German reinsurer from Indian insurers was treated as not taxable in India because the contracts were concluded outside India and the Indian subsidiary and liaison office performed only preparatory or auxiliary functions. The subsidiary's support activities, including data collection, verification, market intelligence, administration, representation and training, were expressly restricted from contract conclusion, negotiation, final documentation or underwriting recommendations, so they did not create a business connection or a fixed place PE. The liaison office was limited to communication functions and could not engage in trading or reinsurance activity. The Revenue also failed to show authority in the subsidiary to conclude contracts or solicit business, so no dependent agent PE existed. Case-Laws Income Tax Fri, 14 Jun 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=301939