CBDT invites stakeholder comments on report pertaining to Profit Attribution to Permanent Establishment in India

Apr 22, 2019 | by Avantis RegTech Legal Research Team

The Department of Revenue on April 18, 2019, has invited comments or suggestions on the proposal for amendment of Rules for Profit attribution to Permanent Establishment.

The Department of Revenue recognizes the significance of issues relating to attribution of profits to a permanent establishment (PE) as well as the need to bring greater clarity and predictability in the applicable tax regime, a Committee was formed to examine the existing scheme of profit attribution to PE under Article 7 of Double Taxation Avoidance Agreements (DTAAs) which specifies the provisions regarding Business profits and recommend changes in Rule 10 of the Income-Tax Rules, 1962 which specifies the provisions regarding determination of income of non-resident. The Committee has submitted its report (Page 3).

In this regard, suggestions or comments of the stakeholders and the general public are invited on the following question:

What your views on the recommendations of the Committee as contained in Section 11 of the Report? 

Comments and Suggestions may be sent electronically (in word format) at the email address [email protected] within 30 days of the publication of the document on the website of the Income Tax Department (www.incometaxindia.gov.in).


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