EY - Navigating in a post-BEPS world: permanent establishments in a post-BEPS world

EY Tax Webcast

Navigating in a post-BEPS world: permanent establishments in a post-BEPS world

Session 4 of 6 part series: “Navigating in a post-BEPS world” series

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Join us as we host a six-part webcast series, "Navigating in a post-BEPS world". These sessions will provide a comprehensive review of BEPS-related developments and associated country action, together with practical implications.

The OECD BEPS project has rapidly moved to the implementation phase, leaving a fundamentally changed landscape in its wake. This new environment requires businesses to re-evaluate their operational and financing structures, identify communications strategies and assess their tax strategy, all with the aim of developing a sustainable tax framework.

This fourth session will discuss the latest developments in the area of permanent establishments (PEs). Join our senior international tax professionals as they discuss:

  • The latest developments in the various regions
  • The status of the work by the Inclusive Framework on BEPS implementation on PEs and the related questions on profit allocation to PEs
  • The options for introducing the BEPS PE changes in bilateral treaties by means of the Multilateral Instrument (MLI), including the expected country positions
  • The new treaty provision in the UN Model Tax Treaty on Services PEs and the practical implications of that change
  • The expected impact of the MAP minimum standard and the availability of mandatory and binding arbitration in country practices

The complete Navigating in a post-BEPS world series:


EY - Jose Antonio (Jano) Bustos

Jose Antonio (Jano) Bustos


Jose Antonio (Jano) Bustos is a member of Ernst & Young LLP’s International Tax Services Practice and the EY Global Tax Desk Network, based in New York. Jano has over 16 years of International Tax and Transfer Pricing experience.

Before joining EY, Jose had different outstanding posts at the Spanish Tax Administration, such as Senior Tax Inspector of the International Taxation Central Unit of the Spanish Tax Agency and Deputy Director General for International Fiscal Affairs, dealing with international taxation and transfer pricing audits, international advance price agreements and mutual agreement procedures and the negotiation of double tax treaties.

EY - Portrait image Ronald van den Brekel

Ronald van den Brekel
EY International Tax Services

Ronald van den Brekel is the Ernst & Young Belastingadviseurs LLP’s leader of the transfer pricing practice in Belgium and The Netherlands. He advises multinational clients in various industries on transfer pricing planning and implementation and operating model effectiveness. He has ample experience in transfer pricing controversy, including unilateral and multilateral APAs.

Before joining EY, Ronald served at the Dutch Tax Administration (DTA) . He has over 20 years of experience as a tax inspector and tax auditor. From 2004 until 2009 he was responsible for transfer pricing within the DTA. He was part of the Bureau of OECD’s Working Party 6, the international rule setting body with regard to transfer pricing, representing The Netherlands.

Ronald holds a graduate degree in Accountancy from the Erasmus University of Rotterdam;  a graduate degree in IT Auditing from the Free University of Amsterdam and a graduate degree in Tax Economics from the University of Tilburg. He is a Dutch Certified Public Accountant (CPA).

EY - Portrait image Ai-Leen Tan

Ai-Leen Tan
EY Global ITS Knowledge Center

Ai-Leen Tan is a member of the EY Global ITS Knowledge Center focusing on permanent establishment issues around the world since 2014. In addition to this role, Ai-Leen is also a member of the EY EMEIA Tax Center Operating Model Effectiveness team based in Zurich.

Prior to this, Ai-Leen worked in Frankfurt am Main, Germany for approximately 10 years, focusing primarily on financial services transfer pricing issues for clients in the banking and capital markets as well as the asset/wealth management sectors. Before moving to Germany, Ai-Leen also worked in Singapore as a legal counsel in the regional South-East Asian headquarters of a major French bank for almost 5 years managing legal risk for the bank’s business divisions with respect to both external and intragroup business transactions.

Ai-Leen graduated with a degree in law (LLB cum laude) majoring in banking and commercial law, as well as a degree in commerce (B Com) majoring in accounting and economics from the University of Melbourne. She has also been admitted to practice as a Barrister & Solicitor of the Supreme Court of Victoria, Australia.


EY - Marlies de Ruiter

Marlies de Ruiter

Global International Tax Services Policy Leader

Marlies de Ruiter recently joined EY and serves as the EY Global ITS Tax Policy Leader, based in the Netherlands. Marlies has vast experience with international tax policy, and specifically with BEPS. Under her leadership, the OECD developed seven of the fifteen actions of the BEPS Action Plan, in particular the actions on tax treaties and transfer pricing.

Marlies was appointed Head of the Tax Treaty, Transfer Pricing and Financial Transactions Division of the OECD’s Centre for Tax Policy and Administration on 1 February 2012. Before joining the OECD, Marlies gained 20 years of experience in the fields of direct taxation and international tax issues with the Dutch Ministry of Finance, first as a specialist on corporate tax issues and transfer pricing, later as the Deputy Director of the International Tax Policy and Legislation Directorate. In this capacity, she led the competent authority function of the Dutch Ministry of Finance and provided leadership to the OECD’s work on tax. She also was the chairperson of Working Party 6, the Working Party responsible for (further) development of the OECD Transfer Pricing Guidelines.