Delhi High Court Says that Liaison and Project Offices Don’t Qualify as ‘Permanent Establishments’

The Tribunal held by the Indian tax authorities noted during an inspection of a Multinational Company (MNC) which set up a liaison office in India. That is the assignees’ activities created a permanent establishment (PE) in India based on the following facts:

The assignee is a non-resident company with its headquarter in Japan, and it only has two projects in India.