A recent Indian public consultation document on amending India’s rules for profit attribution to permanent establishments represents the first time a national government has proposed abandoning the arm’s-length standard. In this article, the authors discuss that document, as well as the OECD’s recent consideration of using formulas to allocate profits to market jurisdictions, and they ponder whether those developments indicate a larger movement away from the arm’s-length standard in favor of a unitary tax system.
Avi-Yonah, Reuven S. "India's New Profit Attribution Proposal and the Arm's-Length Standard." Ajitesh Kir, co-author. Tax Notes Int'l (2019): 1183-90.
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