Reverse Permanent Establishment Case
This query is : Resolved
18 July 2011
Dear Experts, please help me solve the following query:
Suppose there is an Indian company which has a branch in Singapore which is controlled from India.
Further the Singapore (branch) Co. provides some consultancy services (in nature of business income) to the Indian Co.,
Can the Indian Co. be called as the permanent establishment (PE) of the Singapore Co. as under article 5 of the DTAA?
If so, whether such services are chargeable to tax in India as per Article 7 of the DTAA?
Suppose there is an Indian company which has a branch in Singapore which is controlled from India.
Further the Singapore (branch) Co. provides some consultancy services (in nature of business income) to the Indian Co.,
Can the Indian Co. be called as the permanent establishment (PE) of the Singapore Co. as under article 5 of the DTAA?
If so, whether such services are chargeable to tax in India as per Article 7 of the DTAA?
19 July 2011
Branch and Indian Company are one only i.e. Branch is just an extended arm of Indian company. So there is no question of Branch making its Parent Company a PE.
The income of Singapore Branch shall be clubbed in the Indian company accounts.
There shall be Transfer Pricing requirement for the transactions between Indian company and branch office.
Anuj
+91-9810106211
The income of Singapore Branch shall be clubbed in the Indian company accounts.
There shall be Transfer Pricing requirement for the transactions between Indian company and branch office.
Anuj
+91-9810106211
Message likes :
1 times
You need to be the querist or approved CAclub expert to take part in this query .
Click here to login now
Click here to login now
Similar Resolved Queries
Unanswered Queries
- Is this income indian or foreign income?
- ITC temporary reversal and reclaim
- Applicable TDS rate for sale of property in Nov 2024
- Inventory of finished goods
- Can we claim ITC of Feb-2024 in the month of November-2024 which was not claimed by oversight
- Tds on building rent monthly
- Clarification on Documentation of Paid-Up Capital Contribution by Directors
- Quiery in relation to GST liability in case of an advocate who has obtained GST registration.
- RCM INVOICING FROM NOV-2024
- Confusion around Form 26QB fields
- REGARDING ACCOUNTING CODE FOR SERVICE TAX PAYMENT
- Redevolpment of bldg in mumbai
- Refund of AY 22-23
- LAST YEAR 2022-23 ITC IN NEXT YEAR 2023-24 REPORITNG IN GSTR-9
- MIS MATCH OF INVOICE NUMBER
- IGST Credit-Show cause notice issued-confusion
- Issue of gst e invoice
- How to adjusted advances given or receipt
- Foreign vendor without PAN unable to to register due to non receipt of OTP on foreign number ?
- 133(6) DIN INVALID format error - ->WHERE TO REPLY 133(6) notice?
Trending Online Classes
CAclubindia
