PE Risks and Opportunities in International Tax Structuring in the Post-BEPS Era

A permanent establishment can be a tax risk as it often leads to more taxes and compliance obligations, but a permanent establishment can also be used proactively, sometimes aggressively, to manage a group's effective tax rate. Join the IBFD team to explore:
  • When does a permanent establishment becomes a tax risk post-BEPS? How do you manage this risk?
  • Can branches and permanent establishments still be an effective tax structuring tool in the post-BEPS era? If so, how?

Topics Covered

Block 1: PE risks in international tax structures

  • PE considerations in global supply chain structuring
  • PE considerations in business restructuring
  • Ways to mitigate PE risks in global business models

Block 2: Use of PE in international tax structures

  • Use of PE in tax structuring - e.g. branch exemption
  • PE and hybrid branch mismatch structures operational substance examples
  • Anti-abuse rules for branch structures
  • Transparency and disclosure rules for branch structures

Block 3: Cases and Examples

  • Quizzes – identify PE risks and PE uses in international tax structures
  • Exercises – PE risk mitigation
  • Exercises – application of anti-abuse rules to PE structures

Learning Objectives

After participating in this webinar, you will be able to:

  • Identify the permanent establishment (PE) risks associated with global business models
  • Assess options for addressing common PE risks in global business models
  • Compare and contrast the role of PEs in different international tax structures
  • Differentiate between an acceptable use of a PE and uses that may trigger the application of anti-abuse rules


  • Karine Halimi Guez, VP of Tax,
  • Shee Boon Law, Consultant, International Tax and Transfer Pricing
  • Mario Petriccione, Consultant, International Tax

Field of study


Who should participate

This webinar would benefit tax professionals working in multinational groups, tax and legal advisory firms and governments:

  • In-house tax professionals and advisors looking to asses the permanent establishment risks in global business models and develop potential solutions to address these risks
  • Legal professionals assessing the risk of tax controversy associated with the use/presence of permanent establishments
  • Government officials involved in the implementation of OECD/G20 BEPS Action Plan and those responsible for auditing international corporate tax structures

Course level and prerequisites

This is an intermediate-level webinar. Participants in this webinar are expected to have at least 3 to 5 years of experience in international tax and are familiar with the key concepts of international tax law.

Advance preparation

No advance preparation is needed. Participants are expected to be familiar with the key concepts of international tax law.

Interactive webinar – “Group Internet Based” (live webinar only)

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. Participants will also have access to the on-demand version for a further 12 months from the live date.

Date of live broadcast: 18 April 2023

On-demand webinar

On-demand webinars are intended for individual self-study only. Unlike live webinars, they are not open to interactive participation nor do they offer the 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 continuing professional education (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. International Bureau of Fiscal Documentation (IBFD) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of CPE 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 CPE credit – 1 (only applicable to live webinar).

Webinar registration details

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