March 2019

Articles 5, 7 of India-Italy DTAA; Section 9 of IT Act Where liaison office was involved in strategic business decision making in India including price negotiation and agreement finalisation, liaison office would constitute fixed place PE. Employees of a group entity in India carrying on core sale related activities, results in the emergence of a Dependent Agency PE in India

Geeta Jani | Dhishat B. Mehta
Chartered Accountants

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