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India: Subsidiary did not constitute agency permanent establishment under Japan treaty (tribunal decision)

A Tribunal decision concerning whether a foreign company has agency permanent establishment in India

August 6, 2024

The Delhi bench of the Tribunal held that an Indian subsidiary did not constitute an agency permanent establishment (PE) of a nonresident enterprise under the India-Japan income tax treaty because the Indian subsidiary neither had the authority to conclude contracts nor secured orders in India for the nonresident taxpayer.

The taxpayer, a resident of Japan, was engaged in domestic and overseas trading of products like textile, machinery, and minerals. The taxpayer entered into an agency agreement with the Indian subsidiary to provide services to support its sales activities in India and also purchase activities for exporting the goods outside India.

The case is: ITOCHU Corporation

Read an August 2024 report prepared by the KPMG member firm in India

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