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Attribution of Profits to PEs: The Authorised OECD Approach & A Look at the Indian SC Holdings in Morgan Stanley

September 5, 2019[2019] 109 taxmann.com 32 (Article)
The application of transfer pricing provisions to the attribution of profits to permanent establishments (PEs) has received fresh impetus in India after the OECD came up with its authorised approach. The object of this article is to examine the legal status of the application of the transfer pricing provisions qua the attribution of profits to the PEs.
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