India: Crude oil installation facility; PE’s profits | KPMG | GLOBAL

India: Crude oil installation facility; PE’s profits in India

India: Crude oil installation facility; PE’s profits

The KPMG member firm in India has prepared reports about the following developments (read more at the hyperlinks provided below).


Related content

  • Payments for crude oil “single point mooring” (offshore) installation not taxable as royalty: The Delhi High Court held that consideration received for offshore construction and installation of “single point mooring”—including anchor chains and floating and subsea hoses to enable unloading of crude oil from “very large” crude oil carriers to meet the crude oil requirement of taxpayer’s refineries located in the eastern part of India—is not taxable as either a royalty or “fees for technical services” in India. The case is: Technip Singapore Pte. Ltd. Read a June 2016 report [PDF 350 KB]
  • Net global profits attributed to Indian permanent establishment: The Delhi Bench of the Income-tax Appellate Tribunal held that almost all sales functions—including marketing, banking, and after-sales service—were conducted by the taxpayer’s permanent establishment (PE) in India; and therefore, 35% of the net global profits are attributed to the PE in India in respect of hardware and software supplied to Indian customers. The case is: ZTE Corporation. Read a June 2016 report [PDF 344 KB]
  • FAQs on newly introduced tax withholding provisions: Existing provisions require tax withholding (collection) at source and impose a requirement on the seller of certain goods to withhold and collect tax at the specified rates from the buyer of the goods.  Given changes made by the Finance Act, 2016, the Central Board of Direct Taxes issued a list of “frequently asked questions” (FAQs) to clarify the rules. Read a June 2016 report [PDF 291 KB]
  • Levy and collection of cess: With the introduction of Krishi Kalyan Cess (KKC), the Ministry of Finance has issued guidance to give effect to the levy and collection of KKC. Read a June 2016 report [PDF 268 KB]

The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

Connect with us


Request for proposal