The Consultative Group on Tax Policy of the Indian government’s public policy think tank NITI Aayog has issued a working paper on Enhancing Certainty, Transparency and Uniformity in permanent establishment and Profit Attribution for Foreign Investors in India. Among other things, the working paper proposes the introduction of an optional presumptive taxation regime for foreign taxpayers that is meant to avoid permanent establishment and attribution of profits disputes. The key features of t…