India-US Bilateral Tax Relationship

SIFMA, the Investment Company Institute (ICI), the National Foreign Trade Council, Software Finance and Technology Executives Council, United States Council for International Business and the U.S.-India Business Council provide comments to the Internal Revenue Service (IRS) and India’s Department of Revenue on the India-U.S. Bilateral Tax Relationship.  The groups have become increasingly concerned that the rapidly evolving policy views of the Indian Competent Authority and other Indian Revenue authorities on transfer pricing, permanent establishment, and other issues, and their assertion in current cases are impeding the proper operation of the dispute resolution procedures established by the India-U.S. treaty. In addition, the groups warn that the dearth of agreements between the Indian and U.S. Competent Authorities, despite frequent discussions, is without precedent in our experience.