Sorry, you need to enable JavaScript to visit this website.

Operational control over hotels in India creates Hyatt UAE’s ‘permanent establishment’ in India

Submitted by yvonne on Sat, 07/26/2025 - 14:51

In a landmark ruling on a foreign entity’s taxable presence in India, the Supreme Court in Hyatt International Southwest Asia Ltd. v Additional Director of Income-tax, 2025 INSC 891 held that the existence of sustained, pervasive, and enforceable control over a hotel’s strategic, operational, and financial affairs is sufficient to constitute a ‘Permanent Establishment’ (PE) of a foreign enterprise in India.

Date
Practice Area
Type of Insight
Template Type
Publication
Is Ergo
Yes