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UnscheduledInternational 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.


Please note: This course is not currently scheduled. The price, program and instructors are detailed as per the previous course for information purposes only and may be subject to change.
Tax Courses
Amsterdam - The Netherlands
Course code:
Client offer:
20% discount for IBFD Membership clients and 10% discount for Global Tax Explorer (Plus) clients.
Early Bird Discount: a 30% discount will be automatically 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 tax course is designed to provide participants with an in-depth analysis of the concept of permanent establishments (PE). Practical issues, such as the allocation of profits and VAT aspects of PEs, will be covered. The theoretical sessions are complemented by case studies to ensure that participants leave the course with the confidence to apply the knowledge obtained. 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 OECD Base Erosion and Profit Shifting (BEPS) Action Plan, particularly Action 7 (“Prevent the artificial avoidance of PE status”) will be analysed and discussed. PE issues that can arise from tax planning through business restructuring will also be examined.

This is an interactive course with a maximum of 32 participants. Participants will have access to relevant online collections on the IBFD Tax Research Platform for a period of two weeks. Presentations will be made available in electronic format.

Field of study

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 32 participants will be accepted. Early registration is therefore recommended.

Continuing Professional Education

Recommended NASBA CPE points for this course: 20 (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 IBFD International Tax 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 restructuring and permanent establishments
  • Business profits
  • PE and the BEPS project
  • Treaty and EU non-discrimination principles relating to PEs
  • Triangular cases
  • Case studies 
  • Luis Nouel is a Principal Research Associate in IBFD's Knowledge Centre in Amsterdam. Prior to joining IBFD he worked for the International Tax Services group of Ernst & Young in the...
  • Carlos Gutiérrez is a Principal Research Associate at IBFD Tax Services. Mr Gutiérrez obtained his law degree at the University of Chile and a master’s degree (LLM) at Queen...
  • Hans Pijl has Linguistics (MA) and Law (LLM) degrees from the University of Leiden, the Netherlands. He is an independent tax lawyer and of counsel to Deloitte. Previously, he was a partner at...
  • 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...