NIRC recently invited Nitin Narang, Partner– Transfer Pricing and Tarini Nijhara, Associate Director to deliver a session on – Determination of income in case of ‘business connection’/ ‘significant economic presence’. Seminar was fully packed with over 100 professionals and Industry pioneers, The perspectives put forward by  Nitin Narang and Tarini Nijhara during the Event were indeed much appreciated by the audience. They have discussed the below points in their presentation:

• Overview of Article 7 of Model treaties and how profits have been attributed under existing law
• Discussion on relevant transfer pricing provisions of Indian tax laws related to attribution of income
• Discussion of Rule 10 and instances paves its way
• How profits will be attributed in case of digitized businesses

Sharing the presentation represented by Nitin Narang and Tarini Nijhara during the seminar for your ready reference. NIRC_TP Attribution