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

Bulletin for International Taxation 2023

11 Pages Posted: 5 Aug 2024

See all articles by Dhruv Janssen-Sanghavi

Dhruv Janssen-Sanghavi

Maastricht University, Faculty of Law

Riya Bhatt

Field Court Tax Chambers

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

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

Dhruv Janssen-Sanghavi (Contact Author)

Maastricht University, Faculty of Law ( email )

P.O. Box 616
Maastricht, 6200
Netherlands

Riya Bhatt

Field Court Tax Chambers ( email )

3 Field Court
Gray's Inn
London, WC1R 5EP
United Kingdom

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