Comprehensive transfer pricing – 15 Asia Pacific countries – 400 pages: Australia, China, Hong Kong, India, Indonesia, Japan, Malaysia, New Zealand, Philippines, Singapore, South Korea, Sri Lanka, Taiwan, Thailand, Vietnam.
Transfer Pricing ASIA
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Transfer Pricing Asia Overview

Transfer Pricing Asia
Robert Feinschreiber, Esq.
Attorney and Counselor
Margaret Kent, Esq.
Attorney and Counselor
TransferPricingConsortium.com

Permanent Establishment Parameters – Hong Kong Versus India

Governments across Asia are increasingly willing to assert taxation over activities of an alien business doing business that jurisdiction. These governments are more than willing to find that the activities of the alien business create a permanent establishment in that location. This permanent establishment assertion brings with it the taxability of that enterprise in that jurisdiction together with the ensuing transfer pricing considerations. This article compares and contrasts permanent establishment parameters in Hong Kong and in India.

India asserts permanent establishment status based any of the five inquiries: direct business activities, agency relationships, more than stewardship activities, and the power shift personnel, as well as a “entirety of the operations” approach. In contrast, Hong Kong based its permanent establishment activities based on more amorphous standard, “the economically significant activities and responsibilities” of the non-resident enterprise.


Feinschreiber & Associates
Robert Feinschreiber & Margaret Kent

1121 Crandon Blvd. F301
Key Biscayne, FL 33149
Primary Phone: 305.361.5800
or 305.505.9200
Fax: 305.365.2276
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www.transferpricingconsortium.com
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