https://www.taxtmi.com/caselaws?id=31069 AAR examined whether a UAE resident organiser of golf tournaments had a permanent establishment in India under Article 5 of the India-UAE DTAA. It held that the temporary use of golf courses for isolated tournaments did not amount to a fixed place PE because the activity lacked permanence, regularity, and continuity; service PE was also absent because the treaty threshold for furnishing services was not met, and no dependent agent habitually concluding contracts was shown. As no PE existed, the receipts could not be taxed as business profits under Article 7. The ruling further found no other treaty provision, including fees for technical services or other income, that brought the receipts to tax in India. en-us Mon, 13 Oct 2008 00:00:00 +0530 Sat, 17 Sep 2011 15:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=31069 AAR examined whether a UAE resident organiser of golf tournaments had a permanent establishment in India under Article 5 of the India-UAE DTAA. It held that the temporary use of golf courses for isolated tournaments did not amount to a fixed place PE because the activity lacked permanence, regularity, and continuity; service PE was also absent because the treaty threshold for furnishing services was not met, and no dependent agent habitually concluding contracts was shown. As no PE existed, the receipts could not be taxed as business profits under Article 7. The ruling further found no other treaty provision, including fees for technical services or other income, that brought the receipts to tax in India. Case-Laws Income Tax Mon, 13 Oct 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=31069