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OnlineITA103 Permanent Establishments

Permanent establishment is a crucial concept in determining the state in which a non-resident company can be liable to tax. For solid theoretical and practical guidance on this topic, look no further.
 
 
Type:
Online Tax Courses
Language:
English, Chinese
Level:
Intermediate
Price:
EUR 499 / USD 674 (VAT excl.)
Client offer:
20% discount for IBFD Membership clients and 10% discount for Global Tax Explorer (Plus) clients.
 
Ordering multiple courses: to order more than one online course please view our instructions.

 

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 to determine whether cross-border business activities of an enterprise constitute a PE
  • Identify of the consequences of finding a PE in a state

Level

Intermediate
 

Delivery method

QAS Self study
 
Field of study
Taxes
 

Course review

This course was last reviewed mid-2015

 

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.
 
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 8 weeks.

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

Authors:

 
  • Jan de Goede
      Prof. Jan J.P. de Goede, Senior Principal, Tax Knowledge Management, has held several positions at IBFD including Director of the Knowledge Centre. He performs various academic, teaching...
  •  Joanna C. Wheeler
    Dr Joanna Wheeler is a senior member of the IBFD academic group and is currently seconded to the University of Amsterdam (UvA) for a large portion of her time. She is the director of the advanced...

 

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...