India’s tax department must provide greater clarity on when a global company operating in the country can be called a permanent establishment and how its profits would be calculated, a former senior India tax department official said Saturday.
“There is a very dire need in India to have certainty on the aspect of existence of PE and attribution of profits to PE,” said Rajat Bansal, who has represented India in tax treaty negotiations.
“Other than litigation, I don’t think there are any” mechanisms to resolve disputes around this, he said. Bansal was speaking on a panel at a conference ...