IBFD Course Programme International Tax Aspects of Permanent Establishments
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1 IBFD Course Programme International Tax Aspects of Permanent Establishments
2 Overview and Learning Objectives This tax course is designed to provide participants with an in-depth analysis of the concept of permanent establishment (PE). Practical issues, such as the allocation of profits and triangular cases involving PEs, will be covered. The theoretical sessions are complemented by case studies to ensure that participants leave the course with the confidence to apply the knowledge obtained. Emphasis will be placed on a number of complex tax issues relating to PEs, such as non-discrimination, e-commerce, triangular cases and the problems surrounding agency PEs. The OECD Base Erosion and Profit Shifting (BEPS) Action Plan, particularly Action 7 (Prevent the artificial avoidance of PE status), will be analysed and discussed. PE issues that may arise from tax planning through business restructuring will also be examined. This is an interactive course with a maximum of 32 participants. Participants will have access to relevant online collections on the IBFD Tax Research Platform for a period of two weeks. Presentations will be made available in electronic format. Field of Study Taxes Who Should Attend? The course is suitable for practitioners in tax advisory firms, tax specialists in commerce and industry, finance professionals who wish to gain a complete understanding of the subject, tax authorities and government officials. Course Level and Prerequisites This is an intermediate-level course. Participants should be familiar with the structure of tax treaties and their allocation rules in addition to the domestic law of at least one country, in particular as it relates to cross-border situations. 2
3 Day Registration Welcome and IBFD Overview Permanent Establishment Concept Fixed place of business PE Auxiliary and preparatory activities Construction site PE Agency PE Services PE E-commerce issues relating to the PE concept PE concept in the UN Model Relevant case law Break Refreshments Permanent Establishment Concept (continued) Business Restructuring and Permanent Establishments Introduction to business restructuring Business restructuring and PE thresholds Identification of PE risks Practical examples Break Refreshments Case Study 3
4 Day Business Profits Article 7 of the OECD Model (Business profits) Force of attraction and the UN Model Allocation of assets and profits: global methods relevant business activity approach functionally separate entity approach Relevance of functions performed and risks undertaken Financing a permanent establishment Intra- company interest and royalty payments Profits allocation to an agency PE Article 8 of the OECD Model (Shipping, inland waterways transport and air transport) Relevant case law Break Refreshments Business Profits (continued) PE and the BEPS project Final Report BEPS Action 7 Public Discussion Draft on Additional Guidance on the Attribution of Profits to Permanent Establishments Comments received on the Discussion Draft Break Refreshments Case Study 4
5 Day Treaty and EU Non-Discrimination Principles Relating to PEs Non-discrimination principles in the OECD Model Branch profits taxes Double tax relief for withholding taxes attributable to PEs Non-discrimination principles in EU Law ECJ case law on the non-discrimination of PEs Break Refreshments Triangular Cases General remarks Dual resident cases PE as recipient of income PE as source of income Triangular Cases (continued) Break Refreshments Case Study 5
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