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India2025-10en

Enhancing Certainty, Transparency and Uniformity in PERMANENT ESTABLISHMENT and Profit Attribution for Foreign Investors in India

Summary

India faces challenges in attracting and retaining foreign investment due to significant tax uncertainty and compliance burdens, particularly concerning Permanent Establishment (PE) rules and profit attribution for foreign entities. To address this, NITI Aayog proposes a comprehensive framework including an optional, industry-specific Presumptive Taxation Scheme, alongside legislative clarity and improved dispute resolution. This initiative is currently in the planning phase, aiming to boost investor confidence and secure India's tax base.

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