Thursday, 6 June 2013

Agency PE exists only if agent fits into meaning of ‘dependent agent’ provided in Article 5 of India

IT/ILT : In order to treat any agent as PE within meaning of Paras 4 and 5 of article 5 of relevant DTAA it is very vital that such agent should fit into description of 'Dependent Agent' and has to perform either of activities as mentioned in articles 5(4) and 5(5)


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