Tribunal Holds BVI Company Re-Domiciled In Mauritius Entitled To India-Mauritius Tax Treaty Benefits, Also Holds Agency PE To Be Tax Neutral - Tax mondaq.com - get the latest breaking news, showbiz & celebrity photos, sport news & rumours, viral videos and top stories from mondaq.com Daily Mail and Mail on Sunday newspapers.
By
Mariya Paliwala - On January 31, 2021 4:49 pm
The Income Tax Appellate Tribunal (ITAT), Mumbai Bench held that the dependent agent permanent establishment (DAPE) is wholly tax-neutral if the Agent paid remuneration on Arm’s Length Price (ALP).
The assessee, Asia Today Limited is a foreign telecasting company incorporated in Mauritius and having a tax residency certificate of Mauritius. It sells advertising time and collects subscription revenues through its Indian affiliates Zee Telefilms Limited and El Zee, but its claim was that since it does not have any permanent establishment in India, no part of its income was taxable in India.