Agrawal, Mansi
Draft rules proposed by India on profit attribution to permanent establishment an analysis / Mansi Agrawal .-- , 2019
Disponible únicamente en formato electrónico.
Resumen.
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.
ATRIBUCIÓN DE RENTAS
ESTABLECIMIENTO PERMANENTE
IMPUESTOS
INDIA
International Transfer Pricing Journal 1385-3074 v. 26, n. 5, September / October 2019, p. 358-364
Draft rules proposed by India on profit attribution to permanent establishment an analysis / Mansi Agrawal .-- , 2019
Disponible únicamente en formato electrónico.
Resumen.
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.
ATRIBUCIÓN DE RENTAS
ESTABLECIMIENTO PERMANENTE
IMPUESTOS
INDIA
International Transfer Pricing Journal 1385-3074 v. 26, n. 5, September / October 2019, p. 358-364