12 - 15 Mar 2012International Tax Aspects of Permanent Establishments

This course is designed to provide participants with an in-depth analysis of the concept of permanent establishment (PE). Practical issues, such as allocation of profits and VAT aspects of PEs, will be covered.
 
Type:
Open Course
Language:
English
Location:
The Netherlands
Level:
Intermediate
Course code:
OC12PE1
Price:
€ 2,289 / $ 2,861 (VAT excl.)
IBFD Members:
Members receive a 20% discount
 
Early Bird Discount: a 30% discount will be applied for registrations received 60 days or more before the commencement of the course (cannot be used in conjunction with other discounts).
 
International Tax Aspects of Permanent Establishments

Overview and Learning Objectives

This course is designed to provide participants with an in-depth analysis of the concept of permanent establishment (PE). Practical issues, such as allocation of profits and VAT aspects of PEs, will be covered. This will be combined with the use of case studies to ensure that participants leave the course with the confidence to apply what they have learned. 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 latest OECD developments and PE issues that can arise from business restructuring will also be examined.

This is an interactive course with a maximum of 30 participants. Prior to the course, participants will be given access to an documentation platform which provides them with additional pre-reading material and supplementary material (e.g. legal documentation, case law and related articles/literature). During the course, participants will be provided with a course binder containing documents relevant to the course.


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. 
 

Pre-course Preparation

In order to participate in this particular course, no advanced preparation is necessary. However, for some courses, suggested reading materials will be made available on our documentation platform a few weeks before the start of the course.
 

Interactive Course - "Group Live"

To safeguard the interactive nature of the course, including group discussions and case studies, a maximum of 30 participants will be accepted. Early registration is therefore recommended.


Continuing Professional Education

Recommended CPE points for this course: 27 (in accordance with the standards of the National Registry of CPE points, CPE credits are granted based on a 50-minute hour). Read more information on CPE points and accreditation for ITA courses.
 

Course Fee and Registration Details

The course fee covers participation in the course, all course materials, lunch, coffee/tea and refreshments. The costs of accommodation and transport are not covered. If you have any other questions regarding attendance of the course, travel arrangements, payments and cancellations, please consult our FAQ.
  • Permanent Establishment Concept
  • Business Profits
  • Permanent Establishments from an EU VAT Perspective
  • Transfer Pricing Principles
  • Business Restructuring and Permanent Establishments
  • Treaty and EC Non-Discrimination Principles relating to PEs
  • Triangular Cases
  • Case Studies 
  • Roberto Bernales
    Roberto Bernales is a Senior Research Associate in the IBFD European Knowledge Group. He holds a PhD in Tax Law from the...
  • Walter van der Corput
    Walter van der Corput is Editor of IBFD’s International VAT Monitor and EU VAT Compass. He has over 25 years tax...
  • Bart Kosters
    Bart Kosters is a Senior Principal Research Associate in IBFD’s Knowledge Centre. Until January 2010, he was in charge...
  • Shee Boon Law
     
    Shee Boon Law is a Principal Research Associate in IBFD’s International Tax Academy. Prior to joining IBFD, he was a...
  • Hans Pijl
      Hans Pijl is a partner with Deloitte in Amsterdam and is responsible for Deloitte’s Dutch opinion practice....
  • Emanuela Santoro
    Emanuela Santoro is the Tax Director of Fiat Industrial in Turin as from 15 November 2011. Before joining Fiat Industrial, she...