Supreme Court Upholds Delhi High Court Ruling: Indian Subsidiary Does Not Automatically Constitute PE, and No Further Profit Attribution Is Warranted Once the Subsidiary Arm’s Length Remuneration Is Paid
December 5, 2025
The Supreme Court’s affirmation of the Delhi High Court ruling in the Progress Rail case provides important clarity on Permanent Establishment standards in India.
The decision reinforces key principles on control, core functions, agency thresholds, and profit attribution.
It further underscores that arm’s-length remuneration to Indian subsidiaries precludes additional attribution.
A significant development for multinational enterprises evaluating their India-linked operating models.
OBBBA and Qualified Small Business Stock: Bigger, Faster, Broader Section 1202 Benefits for PE, VC and Founders
December 4, 2025
Discover how the One Big Beautiful Bill Act (OBBBA) modernizes Section 1202 QSBS, offering earlier exclusions, higher caps, and broader eligibility for PE, VC, and founders.
Final Buyback Regs Are Good News for M&A Transactions, Too
December 4, 2025
The IRS and Treasury abandoned the embattled “funding rule” in final regulations implementing the 1 percent excise tax on stock buybacks and made welcome changes for reorganizations and preferred stock, tax advisers said.
Non-Executive Director Fees in the FTSE All-Share 2025
December 2, 2025
This year’s Non-Executive Director fees report provides a detailed breakdown of all types of NED fees, as well as our thoughts on recent changes to the regulatory backdrop to NED fees in the UK-listed market.