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The Past, Present and Future of Permanent Establishment

This report attempts to track the evolution of taxation of PEs in India – the how, when and why, and the consequences of establishing the PEs of foreign companies in the country. It first analyses the concept of PE in Indian tax legislations and India’s bilateral tax treaties, and then examines international tax commentaries and landmark Indian judicial precedents, including some recent ones, to gain a clear perspective of how Indian jurisprudence has progressed over the years. It also assesses the potential impact of BEPS AP 7 and the MLI on India’s bilateral tax treaties and how this may affect companies doing and wanting to do business in the country.

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