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WebinarWebinar: Recent International Case Law on Permanent Establishment

This approximately 2-hour interactive webinar is designed to give a brief overview of the latest and most important international cases on permanent establishments (PEs). 
EUR 85 / USD 99 (VAT excl.)
Client offer:

Client offer: 20% discount for IBFD Membership clients and 10% discount for Global Tax Explorer (Plus) clients.
Bulk discount: a 20% discount will be applied to registrations received for 5 people or more made in one order. 

Please note: Registrations to the live webinar will be closed 3 days prior to broadcast and/or when the maximum number of registrations has been reached. Webinars can only be purchased by credit card.
Webinar: Recent International Case Law on Permanent Establishment
Overview and learning objectives
The webinar will help participants to identify and interpret key facts that play an important role in the arguments of tax administrations, courts and taxpayers in deciding whether a PE exists. By selecting the most important and recent cases, as well as giving a thorough explanation of them, the webinar intends to assist the viewers in their future work, so they can manage compliance with the increasingly complex notion of PE and confidently respond to arguments put forward by tax administrations in cases related to PEs. The instructors will also discuss whether the outcome of the cases would have been different considering changes made to the PE concept under BEPS. We will also look at some recent domestic anti-avoidance measures, which will have significant implications on PE structures. Finally, instructors will examine and discuss the two latest international developments concerning permanent establishments: the European Commission’s proposed directives on taxation of digital business activities and the OECD’s latest, extended guidance on profit attribution to PEs.

After following this webinar, you will be able to:

  • identify key risk factors that might lead to the finding of a PE
  • interpret and define the scope of the PE provisions, according to good international practices
  • gain knowledge about the latest international cases on PEs, their relevance, and practical implications
  • apply the guidance laid down by tax administrations, courts and international organizations in solving these cases
  • compare and contrast the EC’s proposal on taxation of digital business activities and the OECD’s new guidance on PE profit attribution

Field of study

Who should participate
The webinar is suitable for all tax professionals, including accountants, in-house tax personnel (e.g. directors, managers), lawyers and tax advisers who deal with cross-border transactions, structures or cases and wish to understand the risks, challenges and controversies related to the PE concept in the post-BEPS world.

Course level and prerequisites
This is an intermediate-level webinar. Participants are expected to be aware of the notion of PE and the practical problems related to it.

Advance preparation
Participation to this webinar does not require any preparation.

Interactive webinar - "Group Internet Based" (live webinar only)
To safeguard the interactive nature of the webinar, a limited number of participants will be accepted. Early registration is therefore recommended. During live webinars, it is possible to interact with the presenters via a chat message function. Please note that questions are answered based on relevance, order of receipt and available time. Additionally, participants in the live webinar are invited to answer poll questions or to complete short tests. Participants will also have access to the on-demand version for a further 12 months from the live date.
Date of live broadcast: 12 April 2018.

On-demand webinar
On-demand webinars are intended for individual self-study only. Unlike live webinars, they are not open to interactive participation or assistance of a real-time instructor. Access to on-demand webinars is granted for a period of 12 months.

Continuing Professional Education
Many accrediting organizations will grant CPE credit(s) for an IBFD audio-visual broadcast. It is advisable, however, that you check with your accrediting body as to whether this applies only to live webinars or to on-demand webinars as well.

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: NASBA possible CPE credits - 2 (only applicable to live webinar​).

Webinar registration details
If you have any questions regarding following the webinar, technical requirements, and payments and cancellations, please consult our FAQ.

  • Setting the scene
  • The most recent international case law on fixed place of business PEs; sales, marketing activities, entities and agents; e-commerce and IT servers; preparatory and auxiliary activities; cross-border workers and construction PEs
  • The impact of BEPS: reinterpreting the outcomes using BEPS Action 7 provisions
  • Latest domestic anti-avoidance measures addressing PE avoidance
    Tamás Kulcsár is a Manager at IBFD’s Tax Services team, as well as contracted expert of the IMF, with over ten years of experience in international tax, transfer pricing and VAT...
  • Emma Barrögård is a Senior Research Associate at IBFD Tax Services. She is involved in tailored tax research projects and in the development of tailored and open courses for tax...
  • 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...