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OnlineITA103 Permanent Establishments

Permanent establishment (PE) is a crucial concept for the taxation of cross-border business activities. The PE online course provides an in-depth analysis of the PE concept and related issues, and includes all recent developments, as well as the changes to the OECD and UN Models resulting from the BEPS Project and the ongoing discussion on the taxation of the digitalized economy. With its structured set of lessons, numerous examples and case studies and extensive reading material, this online course is the ideal toolbox for tax practitioners dealing with cross-border operations.
Online Tax Courses
EUR 499 / USD 674 (VAT excl.)
Client offer:
20% discount for Global Tax Premier clients and 10% discount for Global Tax Explorer (Plus) clients.
Ordering multiple courses:
ITA103 Permanent Establishments

Learning objectives

After completing this course you will be able to:


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



Delivery method

QAS Self study
Field of study

Course review

This course was last reviewed in 2019



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 state, 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.
While this course is suitable for practising professionals, it is also very useful as additional study material in preparing for the CIOT examination - Advanced Diploma in International Taxation (ADIT – Paper 1). Further information about this qualification can be found at the ADIT website.
No advance preparation is needed for this course.


Study time


  • Audio lessons: 4 hours
  • Self study: 19.5 hours
  • Further reading (optional): 44 hours
  • Extra: video interview with international tax expert

Access to the course is granted for a period of 12 months, from the date of ordering. 

Continuing Professional Education (CPE)

The recommended CPE points for this course are as follows:

  • NASBA (The National Association of State Boards of Accountancy, US) - 21.5 points
  • CIOT (The UK Chartered Institute of Taxation) – 23 points
  • NBA (Nederlandse beroepsorganisatie van accoutants) - 23 points

The International Bureau of Fiscal Documentation (IBFD) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have the final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website.

In addition, International Online Tax 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 International Tax Courses.

For more information regarding administrative policies such as complaints and refund, please contact IBFD International Tax Training via email. Please note that once access to an online course has been granted, a refund will no longer be possible.

Order this course now by selecting 'Register Online' above.


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


  • Jan de Goede
      Prof. Jan J.P. de Goede, Senior Principal, Tax Knowledge Management, reports directly to the CEO of IBFD and has held several positions during his 21 years at IBFD, including the role of...
  •  Joanna C. Wheeler
    Dr Joanna Wheeler is a senior member of the IBFD academic group. She established the advanced LL.M. programme in international tax law offered by the University of Amsterdam as a joint project...
  • Giulia Gallo is a Senior Research Associate in IBFD’s European Knowledge Group, serving as Managing Editor of the IBFD publication Permanent Establishments and author of other IBFD...
  • Andreas Perdelwitz is a Principal Research Associate in IBFD’s European Knowledge Group.   Mr Perdelwitz obtained his law degree at the University of Hamburg in 2003 and an LLM in...


Other Contributors:

  • Patrick Ellingsworth, retired Executive Vice President – Tax and Corporate Structure for Royal Dutch Shell plc, is a trustee of IBFD and a regular instructor on IBFD tax courses. Until his...