Taxpayer wins ruling on dependent agents in India
August 28, 2008
The Bombay High Court has ruled that payment of arm’s length remuneration to a Dependent Agent Permanent Establishment (DAPE) in India extinguishes the tax liability of the foreign enterprise
In a reversal of the Income Tax Appellate Tribunal’s (ITAT) decision, the High Court held that where a Dependent Agent (DA) is remunerated on an arm’s-length basis by the foreign enterprise, no further profits can be attributed to the DAPE.
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