Corporate income tax, Dispute resolution, Double Taxation, India, International Tax Law, OECD, Permanent Establishments, Physical presence, Place of taxation, Tax Treaties, United Kingdom, United States
Permanent Establishment: when is business carried on?
Last month my blog discussed the questions relating to corporate residence and article 4(1) of the UK-US Double Tax Treaty raised in G E Financial Investments v HMRC [2021] UKFTT 210 (TC). This month the focus is on the permanent establishment issues. The case concerned a complex financing structure General Electric Company group. The taxpayer,…