Insights
Hyatt ruling: Indian Court sets a new benchmark for determining permanent establishment
August 6, 2025The Hon’ble Supreme Court, in a landmark judgment in the case of Hyatt International Southwest Asia Ltd., has held that Hyatt constitutes a Fixed Place Permanent Establishment (PE) in India under the India-UAE Double Taxation Avoidance Agreement (DTAA).
This decision lays down crucial principles for the PE determination of foreign entities operating in India and could have wide-ranging implications for global businesses with Indian operations.
Our latest Tax Alert provides a detailed analysis of the judgment and outlines key takeaways and the way forward for foreign companies.