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16 January 2019
KNect House, 30-32 Mortimer Street London W1W 7RE,

Permanent Establishments & BEPS Mastercourse

The definitive seminar providing in-depth analysis of PE issues after BEPS for multinational enterprises

Comprehensive analysis of Permanent Establishments in modern international taxation

Essential Case Law

Ensure you gain a thorough understanding of essential case law and critical decisions on the subject, led by our eminent chairman, Jonathan Schwarz. Fundamental case law including 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 will consider 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 Include:

  • Intra Group Management Services
  • Distribution Arrangements, The Digital Economy and BEPS
New for 2019!

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
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 Should Attend?
  • Tax Directors
  • Tax Managers
  • Heads of Tax
  • Tax Accountants
  • International Tax Advisors
Why Attend?

Designed to bring you up-to-date 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 brings together experts in the international tax field, from the legal, banking and accounting professions, and offers the most cutting-edge view in a round table format that is conducive to high level bespoke learning.

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