• Course Brochure: [PDF] download the course brochure

Understanding the PE concept is one thing. Being able to proactively identify possible PEs within an
organization is certainly more difficult. Through the use of case studies and role plays this course looks
at the various scenarios where PEs are commonly overlooked, and which could result in detrimental tax
planning. The course also examines the more complex issues of profit allocation in practice, including the
most current approaches and thinking on the subject.

This is an advanced level course therefore participants should be familiar with the basic issues relating to the PE concept and the attribution of profits, including:

• the role of the PE concept in treaties;
• the essential elements of the PE definition and the differences between the OECD and UN Model
  Conventions;
• current thinking regarding electronic commerce;
• the provisions of Art. 7, the tension between Arts. 7(2) and 7(3) and the OECD Commentary in this
  respect;
• the force of attraction principle and UN Model provisions on profit allocation; and
• the main thrust of the current OECD proposals on profit attribution.