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Indian High Court Holds Significant Role in Contract Negotiations May Constitute PE Under Tax Treaty with U.S.

|Treaty Development|India-United States
India-United States

A 21 December 2018 decision of the Delhi High Court was recently published concerning whether the role played by employees in India in relation to the negotiation of sales contracts was sufficient to constitute a permanent establishment under the provisions of the 1989 tax treaty with the United States. The case involved U.S.-based companies of the GE group (GE Overseas) and their sales operati…

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