Know why Delhi High Court rejected Virtual Service PE to Clifford Chance under DTAA
“The words ‘within a Contracting State’ in Article 5(6) mandate a physical footprint and cannot be expanded to include virtual service permanent establishments.”
Justice V. Kameswar Rao
Part of ICC Sponsorship Payments, for using ICC Trademark, constitutes Taxable Royalty: Delhi High Court
The Court held that the revisional authority was justified in concluding that the payment had two distinct elements, i.e., advertisement and trademark usage.