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Effective Connected’ and ‘Attribution’- Are They the Same? A Myth
Monday Nov 10, 2025

Author: Kunal Arora & Aakanksha Bansal, ASA

In this article, the fine distinction between ‘effectively connected’ and ‘attributable’ income is explored, highlighting how it defines the taxability of cross-border profits linked to a Permanent Establishment. It explains why recognising this difference is vital for accurate profit attribution, treaty interpretation, and reducing international tax disputes.

Published on – Taxmann

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