Abstract

Many Indian tax treaties, in the exclusionary clause of PE article, provide that maintenance of stock for the purpose of delivery does not constitute PE however at the same time Agency PE clause treats a PE to exist when dependent agent regularly delivers goods from such stock. This articles examines this dichotomy and concludes that the exclusionary clause in such cases need to be restricted to 'occasional delivery' and suggests tax planning measures to prevent PE.

Full Text
Paper version not known

Talk to us

Join us for a 30 min session where you can share your feedback and ask us any queries you have

Schedule a call

Disclaimer: All third-party content on this website/platform is and will remain the property of their respective owners and is provided on "as is" basis without any warranties, express or implied. Use of third-party content does not indicate any affiliation, sponsorship with or endorsement by them. Any references to third-party content is to identify the corresponding services and shall be considered fair use under The CopyrightLaw.