09 Oct 2026
Virtual Permanent Establishment — A New Nexus to Tax?
15 Jul 2024
15 Jul 2024
This article was originally published on Tax Notes International on June 24, 2024.
With the digitalization of businesses and the increased use of technology, entities across the globe have adopted digital tools to provide services in jurisdictions despite not having a physical presence there. Countries are increasingly focusing on taxation of services provided by businesses having only a virtual presence. In the recent Clifford Chance ruling, Indian income tax authorities sought to tax the gross receipts of a law firm based in Singapore from clients in India on the basis that the firm had created a permanent establishment in the form of a “virtual service PE” in India. According to tax authorities, a virtual service PE exists when a nonresident entity provides services in another contracting state, without its personnel being physically present in the jurisdiction.
Download PDF
Deal: Trilegal advised Blackstone-backed ASK Investment Managers on its proposed acquisition of SageOne Investment Managers
Deal : Trilegal advises J Infratech on INR 6,000.00 million IPO and an offer for sale of up to 10,000,000 equity shares by the promoter selling shareholders
BRICS 2026: Scaling nature-based carbon credits to empower farmers worldwide
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:
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:
For more information, please read our terms of use and our privacy policy.
