- Danish Tax Council Ruling: On March 6, 2025, the Danish Tax Council ruled that a Swiss company’s activities, which included owning inventory in Denmark and receiving limited logistical support, did not establish a permanent establishment (PE) in Denmark under the Denmark-Switzerland tax treaty, as the activities were deemed preparatory and auxiliary.
- Dependent Agent PE Not Applicable: The ruling clarified that the role of a Danish employee providing procurement support did not create a Dependent Agent PE, as the employee had no authority to negotiate or finalize contracts on behalf of the Swiss company, aligning with prior rulings on PE determinations.
- Indian High Court Decision: On February 21, 2025, the High Court of New Delhi ruled that an Indian subsidiary’s installation of equipment for its Finnish parent did not create a PE in India. The court emphasized that the subsidiary operated independently and was not merely an extension of the parent company, rejecting claims of “virtual projection” and “functional integration.”
Source EY
Latest Posts in "World"
- ERP Integration with Global E-Invoicing: Challenges and Strategies
- Understanding VATs and Tariffs: Essential Tax Principles for U.S. Global Business Success
- IMF Paper Analyzes VAT Efficiency in Revenue Generation and Non-Revenue Objectives
- Renewed Concerns Over Digital Services Taxation as Global Tax Reform Stalls
- E-Invoicing Reimagined: A Fresh Approach to VAT Calculation and Payment
