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UAE to India · PE

Permanent establishment risk for UAE companies in India

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

In brief

A UAE 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–UAE tax treaty: Fixed place, building site and service rules; confirm the day thresholds in the text.

What is specific to UAE companies

Service and building site thresholds in the UAE treaty should be confirmed against the text for each project.

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

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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 UAE rules change often; confirm the current position before acting. UAE law points should be confirmed with a UAE adviser.

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