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International TaxArticle·7 December 2025

Virtual PE created where there is none

By JustIDT

Executive Summary

As global service delivery mushrooms diluting borders amonst nations in the digitial age, the Delhi High Court’s Clifford Chance ruling provides rare clarity that remote services don’t create a PE unless physically performed in India. J the App by JustIDT takes a look at the crucial development for cross-border tax certainty.

Virtual PE created where there is none 

The Delhi High Court’s 2025 ruling in Clifford Chance Pte Ltd

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