The Resource Draft rules proposed by India on profit attribution to permanent establishment : an analysis

Draft rules proposed by India on profit attribution to permanent establishment : an analysis

Label
Draft rules proposed by India on profit attribution to permanent establishment : an analysis
Title
Draft rules proposed by India on profit attribution to permanent establishment : an analysis
Creator
Subject
Language
eng
Summary
The Indian government has issued a draft circular inviting suggestions/comments from the public regarding its examination of the existing approach to profit attribution to a permanent establishment, under article 7 of India's Double Taxation Avoidance Agreements, and regarding the recommended changes to Rule 10 of the Income Tax Rules 1962 designed to bring clarity to domestic law regarding the attribution of profits. The draft rules emphasize a formulary approach to the attribution of profits to a permanent establishment. This article explains the rationale provided by the Indian government for this approach, issues arising from the proposed approach and the impact of the proposed approach on multinational enterprises with operations in India
Citation source
In: International transfer pricing journal. - Amsterdam. - Vol. 26 (2019), no. 5 ; p. 358-364
http://library.link/vocab/creatorName
Agrawal, M
Geographic coverage
Asia
Language note
English
http://library.link/vocab/subjectName
  • transfer pricing
  • allocation of profits
  • PE
  • tax treaty
  • formulary apportionment
  • case law
  • AOA
  • agency PE
  • construction project
  • services PE
Label
Draft rules proposed by India on profit attribution to permanent establishment : an analysis
Instantiates
Publication
Label
Draft rules proposed by India on profit attribution to permanent establishment : an analysis
Publication

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