Article
From Linklaters To Paul Wurth: The Changing Contours Of The Force Of Attraction Rule In Tax Treaties
The Delhi Tribunal's recent ruling in Paul Wurth Italia has reshaped the application of the force of attraction rule under tax treaties, emphasizing that a permanent establishment's mere existence cannot justify taxation of all source-country profits. This decision marks a critical shift toward requiring demonstrable factual and functional nexus between the PE and disputed income, signaling a more restrained interpretation of this contested principle in international taxation.
Lakshmikumaran & Sridharan