AAR ON TAXABILITY OF A CANADIAN COMPANY, HAVING NO PE IN IND
Court :
THE AUTHORITY FOR ADVANCE RULINGS (INCOME TAX) NEW DELHI
Brief :
Where the applicant is in the business of providing bioanalytical services to various pharmaceutical companies around the world, the consideration/fee paid by the Indian pharmaceutical companies to the applicant in respect of bioequivalence tests conducted by it is in the nature of ‘business profits’ under article 7 of the Indo-Canada DTAA and the same is not taxable in India as the applicant does not have a PE in India.
Citation :
Anapharm Inc, In re:
AAR NO. 746 of 2008
September 11, 2008
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CHEZHIYAN
Published in Income Tax
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