Amendment for providing attribution of profit to Permanent Establishment in Safe Harbour Rules under section 92CB and in Advance Pricing Agreement under section 92CC
1 February, 2020
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Attribution to Permanent Establishment now covered in safe harbour rules and advance pricing agreements, providing transfer pricing certainty. Amendments expand Safe Harbour Rules to permit acceptance of declared transfer prices that address attribution of profits to a Permanent Establishment, ... Summary
Attribution to Permanent Establishment now covered in safe harbour rules and advance pricing agreements, providing transfer pricing certainty.
Amendments expand Safe Harbour Rules to permit acceptance of declared transfer prices that address attribution of profits to a Permanent Establishment, and amend Advance Pricing Agreement provisions to allow APAs to determine or specify the manner of determining such attribution, thereby extending transfer pricing certainty to both safe harbour and APA mechanisms for future and rollback years.
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