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Permanent Establishment Attribution of Profit and Transfer Pricing

HomeSeminarBusiness Services FinancePermanent Establishment Attribution of Profit and Transfer PricingPrint 'Permanent Establishment Attribution of Profit and Transfer Pricing'Print Version11/7/2010

Organised By:

Quest India

Type of Event:



Business Services Finance

Event On:

November 18, 2010 - November 18, 2010


Hotel Intercontinental The Lalit Andheri


Mumbai, Maharashtra [India]


The dramatic advances in communications and technology that have taken place in recent years, combined with the progressive development of the Indian economy, have persuaded many multinational companies to tap the rich resources which India has to offer in terms of front line business support services and customer relations. While doing a business in India, some of the multinational companies often create a permanent establishment (PE) in India without their knowledge and in anxiety they end up paying taxes in India.

The basis of determining a PE and attributing profits to the PE are most critical issues in treaty-based international fiscal laws. This is so, because virtually all modern tax treaties use PE as the key instrument to establish taxing jurisdiction over unincorporated business activities of the foreign enterprise in the Source Country. The foreign enterprise's profits from its unincorporated business activities in the Source Country are taxable only if such enterprise has a presence by way of a PE in that country.

For multinational companies, business is very critical aspect and they can't stop doing business in India with the fear of tax liability. Therefore, in order to mitigate the tax exposure in India one needs to understand the basic concept of PE and various nuances attached to it.

The international economy is getting globalized at a faster rate than ever before. Countries are moving towards this integration by bringing their tax laws in consonance with each other. It is in this scenario that transfer pricing assumes great importance. There is a wide spread debate on transfer pricing with respect to varied cross border transactions.

Transfer pricing is a major international tax compliance issue as multinational entities tend to set transfer pricing on cross-border transactions to reduce taxable profits. Transfer Pricing regulation was introduced in India since 1 April 2001 i.e. Assessment Year 2002 - 03. We are now in the 10th year of its operation and have witnessed to its evolvement over a period of time. The Transfer Pricing Regulation has served well to lift the quality of audits in the country and become a source of additional revenue for the government. Further, both the Revenue Departments are working together on customs and transfer pricing harmonisation.

The continued and growing interest of tax authorities in Transfer Pricing and the proliferation of local rules have made the assessment and management of Transfer Pricing risk a key focus for CFOs and tax directors.

There are a number of questions and doubts that people have about PE, attribution of profit to PE, transfer pricing assessment and issues and customs and transfer pricing harmonisation. In order to enlighten the participants about various aspects and key elements pertaining to PE, attribution of profit to PE and transfer pricing, Quest India has organized a one day event entitled Permanent Establishment, Attribution of Profit and Transfer Pricing. Acknowledged experts will be addressing the delegates and would answer individual queries as well.

Who should attend?
• CFOs
• Tax Experts
• Finance Professionals
• Trade & Industry
• Government
• Public Sector Units
• Consultancy Organizations
• Funding Agencies
• Corporate Lawyers
• Banks & Other Financial Institutions

• Fixed Base PE & Service PE
• Basic concept Fixed place of Business & Carrying business through Fixed Place PE and Service PE
• Exception to fixed place of business
• Services rendered through personnel on
• Duration of services
• Interplay between Article on PE and Article on Fees for technical services
• Recent Case Laws
• Construction and Installation PE & Agency PE
• Basic concept
• Duration of activities
• Supervision of services
• Multiple projects
• Basic concept dependent v. Independent agent
• Criteria for determining agency PE
• Recent Case Laws
• Attribution of Profits to PE and its interplay with transfer pricing principles
• Basic principles of business profit taxation
• Principles of profit attribution to PE and relevance of ALP
• Case studies
• Recent Experience in Transfer Pricing Assessment
• Transfer Pricing and Customs Harmonisation
• Panel Discussion


Business Services Service ProvidersBusiness Services Service Providers


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Related Tags Transfer Pricing Assessment, Unincorporated Business Activities, International Economy Event, Tax Compliance Issues


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