PE Risks and Opportunities in International Tax Structuring in the Post-BEPS Era
Group Participation
If you are an enterprise and would like to register a group of more than 5 participants from your company, please email us at info@ibfd.org for more details.
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?
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
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, Booking.com
- Shee Boon Law, Consultant, International Tax and Transfer Pricing
- Mario Petriccione, Consultant, International Tax
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
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.
No advance preparation is needed. Participants are expected to be familiar with the key concepts of international tax law.
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 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.
If you have any questions regarding following the webinar, technical requirements, or payments and cancellations, please consult our FAQ.
