https://www.taxtmi.com/circulars?id=68546 The Committee recommends amending Rule 10 to prescribe objective apportionment formulas for profits attributable to a PE: a three factor apportionment (equal weight to sales, employees/wages and assets) with "profits derived from India" computed as India revenue x global operational (EBITDA) margin subject to a 2% revenue floor; and, where users materially contribute (SEP), a four factor formula including users with weights of 10% (low/medium intensity) or 20% (high intensity), with deductions for profits already taxed in India in the hands of associated resident enterprises. en-us Thu, 18 Apr 2019 00:00:00 +0530 Mon, 28 Apr 2025 16:28:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/circulars?id=68546 The Committee recommends amending Rule 10 to prescribe objective apportionment formulas for profits attributable to a PE: a three factor apportionment (equal weight to sales, employees/wages and assets) with "profits derived from India" computed as India revenue x global operational (EBITDA) margin subject to a 2% revenue floor; and, where users materially contribute (SEP), a four factor formula including users with weights of 10% (low/medium intensity) or 20% (high intensity), with deductions for profits already taxed in India in the hands of associated resident enterprises. Circulars Income Tax Thu, 18 Apr 2019 00:00:00 +0530 https://www.taxtmi.com/circulars?id=68546