Stakeholders apprehend additional guidance on PE-profit attribution would increase uncertainty & double taxation

Oct 11,2017

OECD releases public comments on discussion draft providing additional guidance on attribution of profits to Permanent Establishments (‘PE’) under BEPS Action 7, stakeholders seek greater clarity and certainty; BEPS Monitoring Group (BMG) emphasizes on holistic approach for profit attribution where all the activities carried out by entities in a country would be considered in conjunction, thus considering cumulative importance of activities for evaluation...

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