3 search results for "permanent establishment"

NASSCOM’s submission to CBDT on PE attribution approach

NASSCOM’s has submitted suggestions to Central Board of Direct Taxes (‘CBDT’) on the report of proposed ‘Amendment of rules for profit attribution to Permanent Establishment’ The proposed changes to the rules have been made by a Committee constituted by the CBDT with a mandate to: Examine the existing scheme of profit attribution to PE under the Double Taxation Avoidance Agreements. Examine the co...

Discussion Points on CBDT’s proposal for Amendment of Rules for Profit Attribution to Permanent Establishments (PEs)

Objective The purpose of this document is to discuss the draft report (Report) of the Committee constituted by the Central Board of Direct Taxes (CBDT) on ‘Amendment of rules for profit attribution to Permanent Establishment’. The Report has been issued by the Committee in view of the significance of issues relating to profit attribution to a PE as well as the need to bring greater clarity and pre...

Member consultation: CBDT’s draft rules on attribution of profits to PEs

The CBDT has on 18.04.19 released draft rules (available here) on attribution of profits to permanent establishments. These would have widespread ramifications for multinational companies that are having sales in India or users in India.  The rules appear to be timed with a view to pre-empt the discussions on the digital economy at the OECD/ G20 and could also be a harbinger of the significant eco...