OnlineITA103 Permanent Establishments

Permanent Establishments is a crucial concept in international taxation, as it provides a threshold for determining whether a non-resident company can be liable to tax in a State other than its State of residence. At first glance, it seems like a clear concept, but its interpretation has become more complex, in particular in view of the changes caused by modern ways of doing business, like e-commerce, but also due to the tendency towards granting more taxing rights to the source state. If you want to have a solid theoretical and lively practical guidance on this topic, this course is what you are looking for.
 
Type:
Online Course
Language:
English, Chinese
Price:
€ 499 / $ 674 (VAT excl.)
IBFD Members:
Members receive a 20% discount
 
Ordering multiple courses: to order more than one online course please view our instructions.

 

ITA103 Permanent Establishments

Learning objectives

 

  • Understand the importance of the PE concept in the attribution of taxation rights on profits derived from cross-border business activities
  • Appreciate the variety of ways in which states define equivalent concepts in their domestic law
  • Understand the various types of PE dealt with in both the OECD and the UN Model
  • Ability to determine whether cross-border business activities of an enterprise constitute a PE
  • Awareness of the consequences of finding a PE in a state

Pre-requisites

This course provides an in-depth analysis of the concept of permanent establishments in the context of tax treaties. 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. Participants, particularly those with limited knowledge of tax treaties, are recommended to first complete the course ITA101 Fundamentals of Tax Treaties.

 

Study time

 

  • Audio lessons: 4 hours
  • Self study: 16 hours
  • Further reading (optional): 34 hours
  • Extra: video interview with international tax expert

Access to the course is granted for a period of 8 weeks.

Continuing Professional Education (CPE)


The recommended CPE points for this course are as follows:

  • CIOT (The UK Chartered Institute of Taxation) – 20 points

In addition, ITA Online courses in many cases qualify for CPE credits pursuant to the rules of a number of professional associations other than those listed above. Participants are encouraged to check with their professional and/or national associations to determine eligibility in this respect.

Read more information on CPE points and accreditation for ITA courses.
 

 

 

  • Introduction to the PE Concept
  • Basic rule PE
  • Construction Site PE
  • Services PE
  • Agency PE
  • Special Cases
  • PE Exceptions
  • Consequences of finding a PE

Authors:

 
  • Jan de Goede
    Jan de Goede is Senior Principal, Tax Knowledge Management, reporting to the CEO of IBFD. He previously held several...
  • Joanna Wheeler
    Joanna Wheeler, TEP, is a member of the IBFD academic group. Previously, she was the editor of many different IBFD...
 

Other Contributors:

 
  • Patrick Ellingsworth
    Patrick Ellingsworth is a governing trustee of IBFD and a regular instructor in IBFD’s International Tax Academy. Mr...