Saturday 15 February 2014

Interdependency among Group Company and Indian Subsidiary constitute PE; AAR discusses landmark ruli

IT/ILT: Technical and professional personnel were deputed by applicant to assist its affiliates to optimally execute the contract received by it or its affiliate - The applicant had the power to recall these technical or professional personnel and replace them with other personnel - These personnel would work under the supervision of Indian affiliate - However, the overall control over these personnel was with the applicant – On these facts, whether Indian affiliate shall be deemed to be PE of a


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