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Article 5

AB LLC and BD Holdings LLC v. Commrs. of South African Revenue Services, Case No. 13276, 15 May 2015, South Africa Tax Court -- attach -- Article 5

services PE was not required to be a fixed place of business – and a client boardroom so qualified anyway/double counting of days for 183-day test permitted
  • Read more about AB LLC and BD Holdings LLC v. Commrs. of South African Revenue Services, Case No. 13276, 15 May 2015, South Africa Tax Court -- attach -- Article 5

Centrica India Offshore Pvt. Ltd. v. CIT, W.P. (C) No. 6807/2012 (Delhi High Ct) -- attach -- Article 5

seconded employees remained employees of non-resident
  • Read more about Centrica India Offshore Pvt. Ltd. v. CIT, W.P. (C) No. 6807/2012 (Delhi High Ct) -- attach -- Article 5

31 May 1993 Memorandum (Tax Window, No. 32, p. 15, ¶2613) -- attach -- Article 5

  • Read more about 31 May 1993 Memorandum (Tax Window, No. 32, p. 15, ¶2613) -- attach -- Article 5

Assistant Director of Income Tax, International Taxation, Circle 2(2), Mumbai v. Valentine Maritime (Mauritius) Ltd. (2010), 38 DTR 117 (Mumbai ITAT) -- attach -- Article 5

projects not interconnected
  • Read more about Assistant Director of Income Tax, International Taxation, Circle 2(2), Mumbai v. Valentine Maritime (Mauritius) Ltd. (2010), 38 DTR 117 (Mumbai ITAT) -- attach -- Article 5

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