We have submitted comments, available here, to the OECD on a document issued for public consultation on this subject.
We are surprised that this draft ignores the issue of tax fairness, which is central to tax morale. We also consider it inappropriate to include the data from an earlier survey of business attitudes towards tax certainty, and suggest other sources of evidence about business motivations towards paying tax would be more appropriate.
Read MoreWe have submitted comments on the proposal from India’s Central Board of Direct Taxes to amend the rules on attribution of profits to a permanent establishment, available here.
We commend the CBDT on this proposal, that would introduce a fractional apportionment method for allocation of MNE profits, and provide simplicity, predictability and fairness. Our comments include suggestions for complementing these measures with strengthening of the profit split method for allocation of MNE profits to subsidiaries. This approach offers a roadmap for comprehensive reforms currently debated internationally.
Read More