Permanent establishment tax risks - a regional perspective
8 March 2013, Hong Kong
By invitation only
Most tax authorities in the region have increased their focus on 'permanent establishments (PE)' in their territories. PE risks have always existed, but historically, these have often been technical risks with local assessments difficult to impose and administer. We are seeing a shift in assessing practices in the region in relation to PEs, both in terms whether a PE is created in the first place, and the level of profits that local tax authorities are seeking to attribute to PEs. The Organisation for Economic Cooperation and Development ("OECD") has also recently issued a discussion draft on the revision of the PE commentary in its Model Tax Convention in order to provide clarification in the practical application of the PE article.
In this seminar we will discuss the concept of PE and share our experience and perspective on PEs in the AsiaPacific region. We will explore the international position on PE, looking into the OECD’s 2012 revised discussion draft and double tax agreement PE concepts. We will also discuss transfer pricing as it relates to profits attributable to a PE, as well as managing a mobile workforce and establishing protocols and tools to minimise PE risks in the region.
This seminar will be held at our office on 8 March 2013, at 22/F CITIC Tower, 1 Tim Mei Avenue, Central, Hong Kong.
Our experienced tax professionals will share with you our insights on the following topics:
- PEs in an international context / double tax treaty concepts
- PE developments across the Asia Pacific region
- PE assessment and profit attribution
- Managing PE risk - Human Capital support
|Date:||Friday, 8 March 2013|
|Time:|| 9:00 a.m. – 12:00 midday |
(registration at 8:45 a.m.)
|Venue:||Ernst & Young, 22/F CITIC Tower|
|Address:||1 Tim Mei Avenue, Central, Hong Kong|
|8:45 – 9:00 a.m.||Registration|
|9:00 – 9:05 a.m.||Welcome speech|
|9:05 – 9:35 a.m.||PEs in an international context|
|9:35 – 10:10 a.m.||PE developments across the Asia Pacific region|
|10:10 – 10:40 a.m.||Tea break|
|10:40 – 11:00 a.m.||PE assessment and profit attribution|
|11:00 – 11:20 a.m.||Managing PE risk - Human Capital support|
|11:20 – 12:00 midday||Questions and answers|
Who should attend?
- CEOs, CFOs and senior management of companies
- Tax directors and managers
- Executives and professionals responsible for tax compliance and planning
There will be no fee charge for this event.