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ARTICLE · 03 JANUARY 2017

Delhi HC: Racing Circuit Constitutes Permanent Establishment Of Formula One

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Despite the huge success of the inaugural edition of the Formula One Grand Prix of India held in October 2011 and of the two iterations thereafter in 2012 and 2013 respectively...

IndiaTax
Ritu Shaktawat
Ritu Shaktawat
Ishani Kundu
Ishani Kundu
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Despite the huge success of the inaugural edition of the Formula One Grand Prix of India held in October 2011 and of the two iterations thereafter in 2012 and 2013 respectively, the famous Buddh International Circuit has been conspicuously absent from the Formula One (F1) calendar ever since. One of the reasons for this could be the tax controversy relating to the characterisation of income earned by Formula One World Championship Limited (FOWC) from Jaypee Sports International Limited (Jaypee / Promoter) in India.

The Delhi High Court in its recent ruling Formula One World Championship Ltd v CIT1 has reversed the decision of the Authority for Advance Rulings (AAR) to hold that the Buddh International Circuit constituted a permanent establishment (PE) of FOWC in India.

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