Virtual Service PE - will it be a new reality?

July 24,2017
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Hiten Shah (Executive Director, Ernst & Young)

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  • Sonia Agrawal on Aug 03,2017

    it appears that Saudi Arabia tax authorities have issued internal guidelines whereby 182 days test is applied to the duration of the contract to determine Service PE in Saudi Arabia. While you may be right in interpreting the clause, practically, that is not the position followed in Saudi Arabia.

  • Vijay Goel on Jul 24,2017

    India-Saudi Arabia Article 5 (3) (b): "The furnishing of services, including consultancy services, by an enterprise through employees or other personnel engaged by the enterprise for such purpose, but only where activities of that nature continue (for the same on a connected project) within the country for a period or periods aggregating more than 182 days within any 12-month period." Please see "within the country". Don't you think that this phrase requires the physical presence?