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Permanent Establishment, BEPS & The Digital Economy
January 2021
London
January 2021
London

Permanent Establishments, BEPS & The Digital Economy

The definitive seminar providing in-depth analysis of PE issues surrounding BEPS and the digital economy for multinational enterprises.

Stay up to date to successfully navigate an evolving tax landscape.

Comprehensive analysis of Permanent Establishments in modern international taxation

What was new for 2020?

Permanent Establishment & the Digital Economy:

  • OECD BEPS Action 1
  • OECD Task Force on the Digital Economy
  • Google Ireland in French Courts
  • Unilateral measures
    • Hungarian tax on internet use
    • Indian Equalisation Levy
    • Israel virtual PE
    • US state nexus by receipt of service

Essential Case Law

Delegates gained a thorough understanding of essential case law and critical decisions on the subject, led by our eminent chairman, Jonathan Schwarz. Fundamental case law included decisions by:

  1. French Conseil d’Etat in Zimmer
  2. Norwegian Supreme Court in Dell Products
  3. Spanish Dell and Borax cases
  4. Indian High Court on Formula One
  5. South African Tax Court in AB LLC and BD Holdings LLC v SARS

Interactive Case Studies

Our esteemed panel of international taxation experts considered recent developments in taxing permanent establishments under domestic law and tax treaties, administrative practice and judicial decisions, as well as adherence to, or divergence from, OECD practice using case studies drawn from practical experience.

Case Studies Included:

  • Intra Group Management Services
  • Distribution Arrangements, The Digital Economy and BEPS

In-depth discussions:

  • The meaning of PE and the attribution of PE profits
  • The impact of BEPS Action 7, Diverted Profits Tax and more
  • Interactive panel session – Q&A with the experts
  • Interactive case studies based on current practical problems

Who Attended?

  • Tax Directors
  • Tax Managers
  • Heads of Tax
  • Tax Accountants
  • International Tax Advisors

Why Did They Attend?

This masterclass was designed to bring delegates up to speed on the latest changes in the taxation of cross-border business, whether by foreign companies operating in the UK or UK companies operating abroad. This highly interactive course brought together experts in the international tax field, from the legal, banking and accounting professions, and offered the most cutting-edge view in a round table format that was conducive to high level bespoke learning.