https://www.taxtmi.com/article/detailed?id=17245 Digital-platform distribution requires a distinction between technical standardisation and commercial control. Exclusivity, standard operating procedures, price limits, and inability to modify software or data feeds may be technical requirements of a single global platform and do not alone establish a Dependent Agent PE. Service PE analysis excludes auxiliary stewardship activities and included services qualifying as technical or consultancy services. Where an Indian distributor contracts, invoices, collects fees, and bears risks in its own name, and receives arm's-length compensation for its functions, risks, and assets, further profit attribution to an assumed PE requires additional functions performed in India. en-us Fri, 21 Aug 2026 08:29:00 +0530 Fri, 21 Aug 2026 08:29:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/article/detailed?id=17245 Digital-platform distribution requires a distinction between technical standardisation and commercial control. Exclusivity, standard operating procedures, price limits, and inability to modify software or data feeds may be technical requirements of a single global platform and do not alone establish a Dependent Agent PE. Service PE analysis excludes auxiliary stewardship activities and included services qualifying as technical or consultancy services. Where an Indian distributor contracts, invoices, collects fees, and bears risks in its own name, and receives arm's-length compensation for its functions, risks, and assets, further profit attribution to an assumed PE requires additional functions performed in India. Articles Income Tax Fri, 21 Aug 2026 08:29:00 +0530 https://www.taxtmi.com/article/detailed?id=17245