The Permanent Establishment Issue Of Digital Economy And Profit Attribution To The Permanent Establishment

Under the Significant Economic Presence provisions, a non-resident enterprise might…

 A threshold based on local revenue: “any transaction in respect of any goods, services, or property carried out by a non-resident in India, including the provision of download of data or software in India, if the aggregate of payments arising from such transaction or transactions during the previous year exceeds the amount as may be prescribed”,…

 A threshold based on the number of local users: “systematic and continuous soliciting of its business activities or engaging in interaction with the such number of users as may be prescribed, in India, through digital means”.(72)…