Permanent establishment threshold period under India-Cyprus income tax treaty:
The Delhi Bench of the Income-tax Appellate Tribunal held that the taxpayer did not constitute an installation permanent establishment (PE) under Article 5(2)(g) of the India-Cyprus income tax treaty given the 12-month threshold period was not met. The tribunal observed that preparatory work relating to a contract cannot be counted on calculating the threshold period. The case is: Bellsea Ltd.
Read an August 2018 report [PDF 562 KB] of KPMG