OrbitaxTreaty between India and Germany – Indian decision on profit attribution to a permanent establishment
|Treaty Development|Germany; India
The Indian Income Tax Appellate Tribunal (ITAT) delivered a ruling dated 5 June 2013 in the case of Germanischer Lloyd AG v. DDIT (2013)35 taxmann.com 347 (Mumbai-Trib) on the issue of profit split between a head office (HQ) in Germany and its permanent establishment in India.
(a) Facts. The Taxpayer (i.e. Germanischer Lloyd AG) is a classification society established in Germany and is enga…
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