Book title

Tax Treaty Case Law around the Globe 2025

India: Profit Attribution to Permanent Establishments: Global v. Local

Abstract

The Indian jurisdiction has been long known for bringing up various interesting disputes involving business income and permanent establishments (PE). In the context of PEs, cases involve first and second order questions with the former pertaining to determining the existence and the latter delving into profit attribution.

The recent decision in Hyatt International Southwest Asia Ltd. v. Additional Director of Income-tax (Hyatt) delivered by the New Delhi High Court adds to this set of cases with a significant ruling on the second order question.

Publisher

Linde Publishing

Year

2026

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