Profit Attribution Rules in India: Need for Change


Attribution of profits to a Permanent Establishment (PE) is an area of concern for several MNCs with business operations in India. A broad attribution rule under the Indian tax laws and the lack of specific guidance can result in uncertainty over the amount of profits attributable to a PE.

Recognizing this issue, the Central Board of Direct Taxes (CBDT) established a Committee and has issued a detailed public consultation paper – Report on Profit Attribution to Permanent Establishments. Interestingly, the Committee has adopted a view quite divergent from the OECD approach to profit attribution. The Committee has come up with recommendations on amending the domestic tax rules on profit attribution and has invited suggestions from stakeholders/the general public.

Join USIBC and experts from Dhruva Advisors LLP – Rahul Mitra, Partner and Ajay Rotti, Partner – for an engaging webinar on this subject.

This webinar will provide an insight on the recommendations laid out in the report and discuss its implications for MNCs operating in India.

Day & Date: Thursday, April 25, 2019

Time: 9:00a.m. - 10:00 a.m. EST (6:30pm - 7:30 pm IST)

Venue: Via Call – Prior to the conference call you will receive a presentation attachment. The dial in details are below:

USA: +1-720-259-7053
India, Mumbai: +91 (0)22 6310 0263
India, Chennai: +91 (0)44 6310 0222
India, Bangalore: +91 (0)80 6760 8715
India (toll free): 1.800.3002.1184

Guest Passcode: 506 130 7389

View International Dial-in Numbers

RSVP: Frank Hollowell: fhollowell@usibc.com