Kluwer International Tax Law

Panel Session

Kluwer International Tax Law is delighted to present the panel session:

Permanent Establishment: Latest developments and future outlook

Digital Economy and Permanent Establishment:
Stefan will discuss Permanent Establishment (“PE”) in the digital economy from a comparative perspective. He will focus on a couple of key countries, explain their position and provide a future outlook. In doing so he will refer to the OECD position but his focus will be on these key countries.

Allocation of Profits:
Johann will discuss the allocation of profits to PE’s in general. He will refer to the OECD AOA on the allocation of profits and will note that although many countries follow the regime, others maintain the pre-2008 approach or something in between.

Start and Cessation of Permanent Establishment:
Arvid will speak about the point in time when a PE starts and ceases to exist. This is particularly important for a "construction PE" because there is an exact time limit (duration of 12 months) for a construction PE in which to exist. A day or even hours may determine whether a PE exists or not. It is also important to know these requirements for the basic rule, although the time requirements are more unclear.

Panel members:
Stefan Schmid
PwC Switzerland
Johann Müller
Arvid Aage Skaar
University of Oslo
Panel Session
Tuesday, September 10th, 2019, 7:30am - 9:00am
as part of the 73rd IFA 2019 Congress in London.

LEVEL 6 Westminster Roof Pavilion, Royal Festival Hall
Southbank Centre, Belvedere Road,
London SE1 8XX,
United Kingdom

Breakfast is included