Treaty between Australia and India – No PE in Australia for supply chain activities

On 13 July 2007, The Australian Taxation Office (ATO) released Interpretative Decision ATO ID 2007/143, which deals with supply chain activities of an Indian resident in Australia and whether such activities amount to a permanent establishment in Australia. By way of background, interpretative decisions are explanations provided by the ATO, which, however, are not binding on the ATO.

The facts considered in the Interpretative Decision are as follows: a company r…