Key Recommendation – Presumptive Taxation:
- Optional presumptive taxation regime with sector-specific benchmarks.
- Example:
- Offshore supply → 5% of gross receipts
- Onshore services → 20% of gross receipts
- If a company opts for presumptive taxation, PE existence won’t be litigated separately, giving investors tax certainty.
Permanent establishment (PE):
What is Presumptive Taxation?
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Issues with Current System:
- PE disputes take 6–12 years to resolve.
- Leads to high litigation, blocked resources, and heavy compliance costs.
Why in news?
- NITI Aayog released a paper on Permanent Establishment (PE) and Profit Attribution for Foreign Investors in India.

