Public consultation paper on proposal for attribution of profits to permanent establishment

• Examine existing scheme of profit attribution to PE under Article 7 of Double Taxation Avoidance Agreements (“DTAAs”);
• Examine contribution of demand side and supply side factors in profit attribution; and
• Recommend changes needed to IT Rules to provide specific rules on how profits are to be attributed to a non-resident person having PE in India.

The Committee has submitted a comprehensive report titled ‘Proposal for Amendment of Rules for Profit Attribution to Permanent Establishment’, which the CBDT has made available for stakeholder comments on 18 April 2019.

* This Article is based on the relevant Japanese or specific country’s tax law and other authorities in effect on the date of this Article. This Article would not be guaranteed updating if there are any changes in Japanese tax law, any other law, or interpretations by the courts or tax authorities thereof after the date of this Article.