3. Subsidiary as a Permanent Establishment: Hon'ble Court after analyzing the definition of PE as contained under Article 5 of the DTAA observed that a subsidiary per se does not constitute a PE.
Greg Ip is chief economics commentator of The Wall Street Journal. He writes about U.S. and global economic developments and policy in the weekly Capital Account column and on Real Time Economics, the Wall Street Journalâs economics blog.
About Greg. Greg Owen-Boger is the Vice President of Turpin Communication, a presentation and facilitation training company in Chicago. He started with Turpin as a cameraman in 1995, and quickly moved on to instructor/coach, account manager, and now VP.