Telenor Norway has received a tax assessment according to which the company will have to pay additional taxes in Norway of 2.5 billion Norwegian crowns for tax year 2013. A deduction expenced in 2013 for a loss suffered in 2012 due to settlement of bank guarantees given in respect of external funding in its Indian subsidiary Unitech Wireless has been disallowed for tax purposes by the Norwegian Tax Authorities Telenor decided to enter the market in India in 2008. In 2012, the Supreme Court of India revoked the licenses of the Telenor mobile company and seven other mobile companies. In the fall of 2012, Telenor paid around NOK 4.2 billion to buy back licenses in six of 22 telecommunications regions. Following a dispute with Telenor’s Indian partnership – Unitech – the parties agreed to transfer all the valuables of their joint unit company Mobile Unitech Wireless to a Telenor-controlled company – Telenor India. In the annual report for 2018, Telenor Norway writes that in 2012 the company recognized claims against Unitech Wireless after the company released its guarantee of NOK 10.6 billion for all interest-bearing debt in Unitech Wireless . – deferred tax asset of 2.5 billion Norwegian kroner has been recognized. In 2013, the business transfer from Unitech Wireless to Telenor India was completed and Telenor ASA deducted NOK 9.3 billion as a tax loss in its tax returns. Telenor later withdraw from the Indian market after losses in total of 25 billion ...

India’s Supreme Court found that Formula One World Championship which conducts Formula One racing events, has a permanent establishment (PE) for its business in India and income accruing from it is taxable. “We are of the opinion that the test laid down by the Andhra Pradesh High Court in Visakhapatnam Port Trust case fully stands satisfied. Not only the Buddh International Circuit is a fixed place where the commercial/economic activity of conducting F-1 Championship was carried out, one could clearly discern that it was a virtual projection of the foreign enterprise, namely, Formula-1 (i.e. FOWC) on the soil of this country. It is already noted above that as per Philip Baker, a PE must have three characteristics: stability, productivity and dependence. All characteristics are present in this case. Fixed place of business in the form of physical location, i.e. Buddh International Circuit, was at the disposal of FOWC through which it conducted business. Aesthetics of law and taxation jurisprudence leave no doubt in our mind that taxable event has taken place in India and non-resident FOWC is liable to pay tax in India on the income it has earned on this soil.” “We have held that FOWC has PE in India and income that is attributable in India will be taxed. The amount that is to be taxed is to be assessed by an assessing officer,” a bench of Justices A K Sikri and Ashok Bhushan said ...

In the Vodafone case, the Supreme Court of India found that tax planning within the law will be valid as long as it does not amount to a colourable device ...