of permanent establishments within India. However, its analysis is wide ranging and

applicable to any international situation where the issue of permanent establishment

arises. The book provides a comprehensive and scholarly treatment of Article 7 of the

OECD model treaty, and how it compares to India’s own treaties, as well as an analysis of

Indian case law in this area. In addition to the consideration of the OECD model treaty,

Article 7 of the UN and the US models are also analysed, with comparative analysis

of Article 7 of the tax treaties signed by the United Kingdom, Netherlands and China.

This work, together with the citation of numerous Indian court cases around the question

of permanent establishment, will give the reader insight and ammunition with which

to discuss these issues in relation to any treaty, as definitions and concepts in this area

continue to develop and are as yet to be universally defined.

The work’s particular focus on India is however its main interest to the reviewer. The rise

of India as a major trading hub through improvements in Information Communications

Technology, coupled with the country’s highly educated and English speaking workforce,

have caused many multinationals to invest large sums into the country. This naturally has

given rise to a correspondingly large increase in the number of Indian tax issues that are

faced by international tax practitioners from all industries, many of which are initially in

the arena of permanent establishment and profit allocation as companies take their first

holdings in the country. To many practitioners, the inevitable outcome of this investment

is a difficult and challenging tax audit, where reaching an acceptable and long lasting

agreement with the Indian Revenue can sometimes seem to be an unattainable goal. This

work will be an essential guide to dealing with permanent establishment issues within

India, although what will not be a surprise for the experienced practitioner is that the book

documents several cases where Indian courts have arrived at contradictory conclusions.

In conclusion this comprehensive work could prove an invaluable companion to anyone

dealing with issues in this area, whether Indian focussed or not.