In view of the 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, the CBDT had formed a Committee to examine the existing scheme of profit attribution to PE under Article 7 of DTAAs and recommend changes in Rule 10 of the Income-tax Rules, 1962. The Committee has now submitted its report. The CBDT has sought suggestions/comments of the stakeholders and the general public on the report
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