Archer & Angel - LEGAL UPDATES

Archer & Angel
K-4, South Extension, Part-II
New Delhi 110049
India
ph: (+91)-11-2626-1302
fax: (+91)-11-2626-1303
alt: (+91)-11-4164-1302
info@archerangel.com

LEGAL UPDATES

PE REQUIRES THAT PRINCIPAL IS LEGALLY BOUND BY THE AGENT’S ACTS: Sequel to Dell Case

Article Date: 19 December 2011

In continuation with our earlier update with regard to the judgment of the Borgarting Court of Appeal in the case of Dell Products, it is worthwhile to draw attention to the recent judgment dated 02 December 2011 of the Norwegian Supreme Court which has effectively overruled the order of the Norwegian Court of Appeal and held that the Norwegian company Dell AS acting as a commissionaire agent for Dell Products did not create a permanent establishment for them.

To read the complete analysis click here.

Agency Permanent Establishment: One Body, two souls
Article Date: 21 October 2011
Recently, the Borgarting Court of Appeal, Norway in the case of Dell Products has held that in case a foreign company is found to have a dependent agent permanent establishment (DAPE) in the source country, the dependent agent and the DAPE would be regarded as two distinct tax payers and would be taxed accordingly. Thus, it rejected the single tax payer approach.
We have analysed the Norwegian Court’s Judgement vis-a-vis Indian position and pronouncements. To read the complete analysis click here

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Archer & Angel
K-4, South Extension, Part-II
New Delhi 110049
India
ph: (+91)-11-2626-1302
fax: (+91)-11-2626-1303
alt: (+91)-11-4164-1302
info@archerangel.com

LEGAL UPDATES

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Agency Permanent Establishment: One Body, two souls﻿

Agency Permanent Establishment: One Body, two souls