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
- Capital gain from sale of house property
- TDS on Purchase of Immovable Property by NRI from NRI
- INTEREST APPLICABLE ON ITC REVERSAL PORTION
- Current Account Opening for Sole Proprietorship with Udyam Certificate - Zero Turnover
- Regarding TDS Applicability For Director Remuneration
- Value of property in capital gain
- LC charges in relation to Asset purchased should be Capitalised ?
- Multiple trade mark
- Transporter Declaration form
- FORM 26A APPLICABILITY
- Opting our of sec 44AD
- GST Treatment of Insurance Commission for Existing GST Holder
- Cash gift by grand mother to her grand daughter
- Tax amount diff in Gstr1 and 3B in tax compare reports
- Tds on GST in connection with sale to public company
- Restoration of certificate of practice
- Regarding change in correspondence address in SSP portal
- No Compliences after incorporation
- USEFUL LIFE OF USED/SECOND HAND COMMERCIAL VEHICLES
- Claiming TDS deducted by builder on Hardship compensation and Corpus
Trending Online Classes
-
DT & Audit (Exam Oriented Fastrack Batch) - For May 26 Exams and onwards Full English
CA Bhanwar Borana & CA Shubham Keswani
CAclubindia
