No PE; Subsidiary personnel not rendering services as de-facto employees; Motorola distinguished 


Conclusion

ITAT holds that Article 5(4) of Indo-Swiss DTAA specifically excludes insurance enterprise carrying out reinsurance work from PE definition; Further holds that even in absence of s...

Purchase this Article

2000₹   Buy Now


For 2000₹, purchase this and receive immediate online access.

 

Already a Subscriber?

Log in for complete access.

Log In

Queries?

Contact Vidyadhar Mhatre at +91 93200 54016
Email - sales@taxsutra.com

Top