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PROFIT ATTRIBUTION RULES IN INDIA: TIME TO CHANGE?
Thursday, April 25, 20199:00 am - 10:00 am
Attribution of profits to a Permanent Establishment (PE) is an area of concern for a number of multinational companies with business operations in India. A broad attribution rule under Indian tax laws and the lack of specific guidance can in many cases result in uncertainty surrounding the amount of profits attributable to a PE.
Recognizing this issue, the Central Board of Direct Taxes (CBDT) established a committee, which issued a detailed public consultation paper – the Report on Profit Attribution to Permanent Establishments. In this report, the Committee adopted a view that diverges significantly from the OECD approach to profit attribution. The Committee also issued recommendations on amending the domestic tax rules on profit attribution and has invited suggestions from stakeholders/the general public. If adopted, the recommendations would likely impose a larger tax liability on multinational companies operating in India.
Join USIBC and experts from Dhruva Advisors LLP – Rahul Mitra, Partner and Ajay Rotti, Partner – for an engaging webinar on this subject. The webinar will provide insight into the recommendations laid out in the report and discuss its implications for MNCs operating in India, as well as provide a platform for feedback on the Committee’s recommendations.
Please RSVP to Frank Hollowell in advance of the call to receive dial-in details.