Aramco India Not a Permanent Establishment Under Article 5(8) of DTAA for Services to Applicant Company.

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....Fixed Place PE - essential ingredients of a Service PE - services rendered to the Applicant company by its Indian affiliate - Aramco India is a separately incorporated legal and taxable entity, and by virtue of para (8) of Article 5 of the DTAA, it does not automatically become a PE of the Applicant.....