Social media profiles used as evidence of PE

ConstantinosInternational Tax0 Comments

Recently, the Delhi Bench of the Income Tax Appellate Tribunal (the tribunal) in the case of GE Energy Parts Inc v ADIT (ITA No. 671/Del/2011) held that the LinkedIn profiles of the employees of the GE group submitted by the tax authorities were admissible as evidence in determining the existence of a PE in India. The tribunal’s view was that … Read More

Definition of residence for Cyprus entities

ConstantinosCorporate Income Tax, Cyprus tax0 Comments

The term “residence” is defined in section 2 of the Cyprus Income Tax Law.  It is of a great importance as companies tax resident in Cyprus are taxed at their worldwide incomes under Income tax or other applicable taxes (mainly Defence Contribution) Companies A company is resident in Cyprus if its management and control is exercised in Cyprus. Cyprus tax laws … Read More