On 18 April 2019, the Central Board of Direct Taxes (CBDT) released the Committee’s report on profit attribution to a permanent establishment (PE) in India for public consultation, specifically requesting for comments on the conclusions and recommendations, having regard to the objectives and policy rationale underlying the recommendations. The report was prepared by a committee formed to examine the existing scheme of profit attribution to PEs under article 7 of tax treaties concluded by India, as well as recommend changes to Rule 10 of the Income Tax Rules, 1962.

Comments and suggestions may be sent electronically (in word format) at the email address usfttr-1@gov.in within 30 days of the publication of this document on website of the Income Tax Department.