An eye opening insight into new legislation and possible future trends

- Jonathan Sebire, Marlborough Trust Company Ltd

Permanent Establishment

Permanent Establishment

Introduction

Programme highlights

  • UK taxation of non-resident corporate entities and relevance of permanent establishment concept in the UK tax system
  • The UK domestic concept of permanent establishment and its relevance in a non-treaty context:
    - fixed place of business
    - building sites, construction and installation projects
    - the concept of agency PE with particular regard to common law
    - the concept of independent agency
    - the exemption for auxiliary and preparatory activity
  • The OECD concept of permanent establishment and key differences with the UK domestic concept, in particular:
    - time condition
    - authority to conclude contracts vs authority to do business
    - exemption for auxiliary and preparatory activity
    - shareholding relationship
  • Interaction between UK domestic principles and double tax treaty provisions in line with the OECD Model Tax Convention with particular regard to the permanent establishment concept and its profits
  • Overview of attribution of profits to permanent establishment in light of both UK and OECD principles (please note that this will only be an overview as this topic is normally covered by transfer pricing specialists)

Event details


Date:

Friday 12 November 2010

Location:

To be advised LONDON
London

6 CPD
Hours

Who Should Attend

Tax accountants and lawyers working in-house or in an advisory capacity