https://www.taxtmi.com/highlights?id=103856 Article 5(2)(l) of the India-USA DTAA requires cumulative satisfaction of services being furnished or performed in India through employees or other personnel for the prescribed period before a service permanent establishment arises. Cost-to-cost reimbursements of expenditure initially incurred and later cross-charged without mark-up do not establish such a presence where the activity is performed remotely and the non-resident's employees or personnel have no physical presence in India. In those circumstances, no service permanent establishment or taxable income in India arises from the reimbursements. en-us Thu, 17 Sep 2026 07:52:26 +0530 Thu, 17 Sep 2026 07:52:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=103856 Article 5(2)(l) of the India-USA DTAA requires cumulative satisfaction of services being furnished or performed in India through employees or other personnel for the prescribed period before a service permanent establishment arises. Cost-to-cost reimbursements of expenditure initially incurred and later cross-charged without mark-up do not establish such a presence where the activity is performed remotely and the non-resident's employees or personnel have no physical presence in India. In those circumstances, no service permanent establishment or taxable income in India arises from the reimbursements. Highlights Income Tax Thu, 17 Sep 2026 07:52:26 +0530 https://www.taxtmi.com/highlights?id=103856