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What is Profit Attribution to Permanent Establishments about?

The document discusses the proposals from a CBDT committee regarding profit attribution to permanent establishments (PEs) in India, emphasizing the need for clarity and consistency in domestic rules. It outlines various approaches to profit attribution, rejecting the FAR method in favor of a formula-based approach that considers both demand and supply factors. The committee suggests a fractional apportionment method for determining profits attributable to PEs, particularly in light of India

Author

anjalishikne

Language

EN