Indian Court Holds Service PE may be Constituted even in the Absence of Physical Presence under U.A.E. Treaty

The Bangalore Income Tax Appellate Tribunal has recently issued a decision in a case that involved a taxpayer based in the United Arab Emirates that engaged in regional service activities for ABB Group legal entities under a regional headquarters service agreement that covered India, as well as Africa and the Middle East. The service activities included consulting services for an India-based en…
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