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OnlineITA106 Business Profits

Learn about tax treaty rules applicable to business profits and the approaches states may take in attributing profits to permanent establishments. Identify differences between the business profits articles in the OECD and the UN Models.
Online Tax Courses
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
ITA106 Business Profits

Learning objectives

After completing this course you will be able to:


  • Recognize the importance of business profits articles in tax treaties to the attribution of taxation rights on cross-border business activities
  • Identify the differences between the business profits articles in the OECD and the UN Models
  • Fully grasp the various approaches states may take in attributing profits to permanent establishments
  • Identify the areas of potential difficulty in connection with the treatment of internal dealings between PEs and other parts of the enterprise
  • Distinguish recent developments with respect to the attribution of profits to PEs



Delivery method

QAS Self study
Field of study


This course introduces the tax treaty rules applicable to business profits. Participants should be familiar with the basic principles of tax treaties in addition to the domestic law of at least one country, in particular as it relates to the taxation of cross-border income, and should be familiar with the permanent establishment concept as the course takes you from the basic ideas through to the more complex concepts. Participants, particularly those with limited knowledge of tax treaties, are recommended to first complete the course ITA101 Fundamentals of Tax Treaties and ITA103 Permanent Establishments.
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: 3 hrs 15 mins
  • Self study: 5 hrs 30 mins 
  • Further reading (optional): 39 hrs
  • Extra: 40 min video interview with international tax expert, Philip Baker QC

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) - 11 points
  • CIOT (The UK Chartered Institute of Taxation) – 9 points
  • NBA (Nederlandse beroepsorganisatie van accountants) – 9 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 complain and refund, please contact the 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 business profits
  • OECD and UN Models – Overview of Art. 7
  • Approaches to profit allocation
  • Attribution of revenues and expenses
  • Internal dealings
  • Introduction to advanced topics


  • Harry Tonino is a qualified lawyer specializing in international taxation, with several years of international professional experience gained working with top-tier law firms, leading global...
  • Bart Kosters
    Bart Kosters is a Senior Principal Research Associate in IBFD’s Tax Services Department in Amsterdam. He has over 30 years of experience in domestic and international taxation. His areas of...


Other Contributors:

  • Philip Baker is a barrister and Queen's Counsel practising from Field Court Tax Chambers in London. He specializes in international tax issues, with a particular interest in double tax...
  • Joel Cooper
    Joel Lachlan Cooper is Co-Head International Transfer Pricing Group at DLA Piper, based in London, United Kingdom. He provides clients with a fresh perspective on complex transfer pricing matters...
  • 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. She established the advanced LL.M. programme in international tax law offered by the University of Amsterdam as a joint project...