https://www.taxtmi.com/caselaws?id=462691 A foreign reinsurer's Indian tax exposure depends on whether its Indian support arrangements amount to a business connection or permanent establishment under domestic law and the India-Ireland DTAA as modified by the MLI. The article states that the reinsurer's core risk-assumption activity was carried on outside India, while the Indian service entity performed support functions on an arm's length basis. It further explains that the anti-fragmentation rule applies only where source-State activities are complementary functions forming a cohesive business operation. On the stated facts, the Indian entity's support work did not create a fixed place PE, a dependent agent PE, or a modified-treaty PE, so the income was not taxable in India on that basis. en-us Wed, 22 May 2024 00:00:00 +0530 Wed, 09 Jul 2025 12:54:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462691 A foreign reinsurer's Indian tax exposure depends on whether its Indian support arrangements amount to a business connection or permanent establishment under domestic law and the India-Ireland DTAA as modified by the MLI. The article states that the reinsurer's core risk-assumption activity was carried on outside India, while the Indian service entity performed support functions on an arm's length basis. It further explains that the anti-fragmentation rule applies only where source-State activities are complementary functions forming a cohesive business operation. On the stated facts, the Indian entity's support work did not create a fixed place PE, a dependent agent PE, or a modified-treaty PE, so the income was not taxable in India on that basis. Case-Laws Income Tax Wed, 22 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462691