OrbitaxIndian Tribunal Holds Franchise in India Does Not Constitute PE under Tax Treaty with the U.S.
|Treaty Development|India-United States
The Mumbai Income Tax Appellate Tribunal issued a decision on 29 June 2018 concerning whether an Indian franchisee constitutes a dependent agent permanent establishment (PE) for the U.S. franchise owner.
The case involved U.S. franchise owner Domino's, which entered into a master franchise agreement with an Indian company, Jubilant Foods, for franchise stores in India. Under the agreement, Ju…
Continue Reading
