https://www.taxtmi.com/caselaws?id=33619 A liaison office in India was not a Permanent Establishment under Article 5 of the India-Korea tax convention because a fixed place qualifies only if the enterprise carries on business wholly or partly through it. The office was restricted by RBI approval to communication and support functions, and could not conduct trading, commercial or industrial activity, enter contracts, or render consultancy services. Its activities were limited to collecting information, market reporting, and other preparatory or auxiliary functions, so it did not amount to a Permanent Establishment. en-us Fri, 29 May 2009 00:00:00 +0530 Sat, 30 May 2009 00:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=33619 A liaison office in India was not a Permanent Establishment under Article 5 of the India-Korea tax convention because a fixed place qualifies only if the enterprise carries on business wholly or partly through it. The office was restricted by RBI approval to communication and support functions, and could not conduct trading, commercial or industrial activity, enter contracts, or render consultancy services. Its activities were limited to collecting information, market reporting, and other preparatory or auxiliary functions, so it did not amount to a Permanent Establishment. Case-Laws Income Tax Fri, 29 May 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=33619