PE Watch | Latest developments and trends, May 2023

• India exempts offshore services connected to Indian permanent establishments from tax under the India-Germany tax treaty. The Bangalore bench of the Income Tax Appellate Tribunal ruled that the distribution of online advertising does not create a permanent establishment in India.
• The Danish Tax Board ruled that gas storage activities in Denmark do not constitute a permanent establishment for a German company.
• The Spanish General Directorate of Taxes ruled that warehousing activities by a third party do not create a permanent establishment, but a local distributor may qualify as an agent.

Source EY

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