[INDIA] AIC submits comments on India’s Rules for Profit Attribution to Permanent Establishment to Central Board of Direct Tax (May 2019)

Download: [INDIA] AIC submits comments on India’s Rules for Profit Attribution to Permanent Establishment to Central Board of Direct Tax (May 2019)

The Asia Internet Coalition (AIC) has submitted comments to the Central Board of Direct Tax (CBDT), on the proposal for Amendment of Rules for Profit Attribution to Permanent Establishment in India. The objective of this submission is to provide comments and recommendations to the report of the Committee constituted by the CBDT on ‘Amendment of rules for profit attribution to Permanent Establishment’ (‘Report’).  We commend CBDT on proposing the changes in the methodology for taxing multinational companies, including digital firms, having permanent establishment (PE) in India by giving weightage to factors like domestic sales, employee strength, assets and user base. We also recognize the significance of issues relating to attribution of profits to a permanent establishment as well as the need to bring greater clarity and predictability in the applicable tax regime.