Download This PaperAttributing Profits to a Former PE & Other Issues: A Critical Comment on the Interpretation of the UK-India Tax Treaty in the SIS Live Case
Bulletin for International Taxation 2023
11 Pages Posted: 5 Aug 2024
Date Written: October 10, 2023
Abstract
The authors analyse critically the approach adopted by the Indian Income Tax Appellate Tribunal whilst applying the India-UK Tax Treaty (1993) in the recent case of SIS Live (2023). They address important questions about the existence of, and timing issues in attributing income to, permanent establishments, and about judicial propriety.
Keywords: permanent establishment, tax treaties, international tax, judicial propriety, losses, jurisdiction, tax, law
JEL Classification: K34, K42
Suggested Citation: Suggested Citation
Janssen-Sanghavi, Dhruv and Bhatt, Riya, Attributing Profits to a Former PE & Other Issues: A Critical Comment on the Interpretation of the UK-India Tax Treaty in the SIS Live Case (October 10, 2023). Bulletin for International Taxation 2023, Available at SSRN: https://ssrn.com/abstract=4687191
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