https://www.taxtmi.com/news?id=21267 The Committee recommends amending rule 10 to adopt an objective apportionment for profits attributable to Indian operations where separate accounts are unavailable: a three factor formula equally weighting sales, employees (manpower & wages) and assets applied to 'profits derived from India' (revenue from India x global operational profit margin), with a 2% deemed profit floor where global margins are negative or below 2%. For enterprises meeting SEP via user thresholds, a four factor formula including a user factor (10% weight for low/medium user intensity; 20% for high user intensity) is to be applied, with credits/deductions to avoid double taxation when Indian associated enterprises are already taxed. en-us Thu, 18 Apr 2019 18:51:26 +0530 Wed, 11 Feb 2026 15:58:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/news?id=21267 The Committee recommends amending rule 10 to adopt an objective apportionment for profits attributable to Indian operations where separate accounts are unavailable: a three factor formula equally weighting sales, employees (manpower & wages) and assets applied to 'profits derived from India' (revenue from India x global operational profit margin), with a 2% deemed profit floor where global margins are negative or below 2%. For enterprises meeting SEP via user thresholds, a four factor formula including a user factor (10% weight for low/medium user intensity; 20% for high user intensity) is to be applied, with credits/deductions to avoid double taxation when Indian associated enterprises are already taxed. News - Thu, 18 Apr 2019 18:51:26 +0530 https://www.taxtmi.com/news?id=21267