Virtual Service PE Can’t Be Read Into DTAA; No Service PE Without Physical Presence: Delhi High Court

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Virtual Service PE Can’t Be Read Into DTAA; No Service PE Without Physical Presence: Delhi High Court

Direct Tax

Published on

08/12/2025

By Mariya Paliwala

Virtual Service PE Can’t Be Read Into DTAA; No Service PE Without Physical Presence: Delhi High Court

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The Delhi High Court has held that a Virtual Service Permanent Establishment (PE) cannot be created without explicit provision in the India–Singapore DTAA, and that physical presence of employees in India is essential for constituting a Service PE under Article 5(6). The bench of . Justice V. Kameswar Rao and Justice Vinod Kumar has dismissed…

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Mariya Paliwala https://www.jurishour.in/

Mariya is the Senior Editor at Juris Hour. She has 7+ years of experience on covering tax litigation stories from the Supreme Court, High Courts and various tribunals including CESTAT, ITAT, NCLAT, NCLT, etc. Mariya graduated from MLSU Law College, Udaipur (Raj.) with B.A.LL.B. and also holds an LL.M. She started her career as a freelance tax reporter in the leading online legal news companies.

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Virtual Service PE Can’t Be Read Into DTAA; No Service PE Without Physical Presence: Delhi High Court

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