https://www.taxtmi.com/caselaws?id=424118 An Indian liaison office will not constitute a permanent establishment under Article 5 of the Indo-Mauritius tax treaty where the evidence shows that its functions are limited to coordination, logistics, communication, and supplying information, without substantial business activity being carried on from the premises. The treaty exclusion for a place of business maintained only for preparatory or auxiliary activities applies on those facts, and such a finding is treated as factual and not perverse where supported by the record. The alternative limb of Article 5 becomes academic once the principal exclusion is satisfied. en-us Wed, 08 Jun 2022 00:00:00 +0530 Wed, 22 Jun 2022 09:15:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=424118 An Indian liaison office will not constitute a permanent establishment under Article 5 of the Indo-Mauritius tax treaty where the evidence shows that its functions are limited to coordination, logistics, communication, and supplying information, without substantial business activity being carried on from the premises. The treaty exclusion for a place of business maintained only for preparatory or auxiliary activities applies on those facts, and such a finding is treated as factual and not perverse where supported by the record. The alternative limb of Article 5 becomes academic once the principal exclusion is satisfied. Case-Laws Income Tax Wed, 08 Jun 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=424118