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
Click on the Download link below to access complete article.
Download Pdf