Chartered Accountants◆Practising since 2016

Singapore to India · PE

Permanent establishment risk for Singapore companies in India

CA Utsav Dogra, Chartered Accountant, ICAI M. No. 542375 · Updated

In brief

A Singapore company that has a fixed place, a dependent agent or a long project in India can become taxable in India on the profits attributable to it. Under the India–Singapore tax treaty: Service PE threshold: over 90 days in a fiscal year, cut to 30 days where the services go to a related enterprise.

What is specific to Singapore companies

The 30-day service PE test for associated enterprises is unusually short, so track visits by Singapore managers to the Indian centre.

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We price, document and defend intercompany transactions on the Indian side.

  • Functional analysis and benchmarking
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Questions

Does having a subsidiary create a PE for the parent?

Not by itself. Risk arises from what parent staff or the subsidiary's people do on the parent's behalf.

General information as at 5 November 2026, not advice for a particular case. Indian and Singapore rules change often; confirm the current position before acting. Singapore law points should be confirmed with a Singapore adviser.

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