Permanent Establishments

Hyatt Ruling Expands Horizons

In Episode 1, our Partner Himanshu Sinha discusses the Supreme Court’s ruling on permanent establishment in India, in the context of the Hyatt International case. He explains how effective control and continuous business connection are evaluated by the Court for PE determination in India. He also discusses the Court’s conclusions on what creates a taxable presence for foreign entities in India.

Play Video

Playing Now
Guardrails for Foreign Operators in India

Our Partner, Himanshu, explains what foreign entities can do to avoid PE disputes in India under the Supreme Court’s PE ruling in the case of Hyatt International. He discusses the mitigation of PE risk in India through robust inter-company contracts and transfer pricing documentation, as well as other strategic approaches.

Play Video

Playing Now
NITI Aayog Report

In this final episode, Himanshu focuses on some of the key recommendations discussed in the NITI Aayog report regarding profit attribution in India for PEs. He discusses the optional presumptive tax regime with industry-specific profit margins suggested under the report to compute taxable income, and highlights the potential concerns arising out of this recommendation.

Play Video

Playing Now

Latest Videos

Rights Issues by Listed Companies

24 Mar 2026

Employee Investigations

12 Mar 2026

Managing ESOPs in M&A Transactions

02 Mar 2026

Understanding Securitisation

27 Feb 2026

Future-Proof Your Deal

11 Feb 2026

Start-Up Funding – Investor Rights

27 Jan 2026

Preparing for an IPO – Some Founder Challenges

16 Jan 2026

Subscribe to our Knowledge Repository

If you would like to receive content directly in your inbox from our knowledge repository, please complete this subscription form. This service is reserved for clients and eligible contacts.

First Name: *

Last Name: *

Organisation: *

Role: *

Official Email ID: *

Your Contact at Trilegal:

Location *

Disclaimer

Under the rules of the Bar Council of India, Trilegal is prohibited from soliciting work or advertising in any form or manner. By accessing this website, www.trilegal.com, you acknowledge that:

You are seeking information about Trilegal of your own accord and there has been no form of solicitation, advertisement or inducement by Trilegal or its members.
This website should not be construed as providing legal advice for any purpose.
All information, content, and materials available on this website are for general informational purposes only.
Any information obtained or material downloaded from this website is completely at the user’s volition, and any transmission, receipt or use of this website is not intended to, and will not, create any lawyer-client relationship.
Information on this website may not constitute the most up-to-date legal or other information. Trilegal is not liable for the consequences of any action taken by any person based on any material or information available on this website, or for any inaccuracy in or exclusion of any information or interpretation thereof.
Readers of this website or recipients of content or information available on this website should not act based on any or all such content or information, and should always seek advice of competent legal counsel licensed to practice in the appropriate jurisdiction.
Third party links contained on this website re-directing users to such third-party websites should neither be construed as legal reference / legal advice, nor considered as referrals to, endorsements of, or affiliations with, any such third party website operators.
The communication platform provided on this website should not be used for exchange of any confidential, business or politically sensitive information.
The contents of this website are the intellectual property of Trilegal.

We prioritize your privacy. Before proceeding, we encourage you to read our privacy policy, which outlines the below, and terms of use to understand how we handle your data:

The types of information we collect and why we collect them.
How we use your information to provide a personalized experience.
The measures we take to ensure the security of your data.
Your rights and choices in managing your personal information.
How we may share information with trusted partners for specific purpose.

For more information, please read our terms of use and our privacy policy.