Abstract
In this article, the authors highlight the increasing move by the Indian tax authorities towards adoption of the profit split method of allocating profits of multinational enterprises which undertake operations in India, particularly in relation to marketing intangibles, permanent establishments and contract research and development centres. The article canvasses recent Income Tax Appellate Tribunal decisions and highlights the need for multinational enterprises to protect themselves from the tax authority’s newfound thirst for the profit split method by carrying out detailed functional analyses, which are comprehensively documented.
Talk to us
Join us for a 30 min session where you can share your feedback and ask us any queries you have
Schedule a callDisclaimer: All third-party content on this website/platform is and will remain the property of their respective owners and is provided on "as is" basis without any warranties, express or implied. Use of third-party content does not indicate any affiliation, sponsorship with or endorsement by them. Any references to third-party content is to identify the corresponding services and shall be considered fair use under The CopyrightLaw.
