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Corporate Tax

07 June 2019
Pranay Bhatia CBDT issues draft report on attribution of profits by permanent establishments

India - BDO LLP

Due to the uncertainty and unpredictability resulting from the application of Rule 10 of the Income Tax Rules, the Central Board of Direct Taxes formed a committee to examine the existing profit attribution scheme. The committee recently issued a report on this issue and is seeking comments from stakeholders. Broadly speaking, the report suggests amending Rule 10 to adopt a three-factor method to attribute profits with equal weight to sales (a demand-side factor) and manpower and assets (supply-side factors).

Author: Pranay Bhatia
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