Google India, Google Ireland and Google LLC, USA before Income Tax Appellate Tribunal, Bengaluru

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Apr 03, 2023

Google India, Google Ireland and Google LLC, USA before Income Tax Appellate Tribunal, Bengaluru

AZB & Partners represented Google India, Google Ireland and Google LLC, USA before Income Tax Appellate Tribunal, Bengaluru and was successful in getting their tax assessments (along with appellate orders) quashed on international tax issues involving existence of Dependent Agent Permanent Establishment (“DAPE”), taxation of payments for purchase of online advertisement space as Royalty and taxation of reimbursement for salary cost of seconded employees treated as Fees for Technical/ Included Services (“FTS”/”FIS”) as provided for in Double Taxation Avoidance Agreements between India and Ireland as well as India and USA.

The AZB team was led by Mr. Deepak Chopra, Senior Partner, Mr. Anmol Anand, Senior Associate and Ms. Priya Tandon, Senior Associate.

AUTHORS & CONTRIBUTORS

Partner:
Deepak Chopra

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