EY - Are you crossing the threshold? Changing permanent establishment and other nexus rules

EY Webcast Series: Advancing in a global tax environment in flux

Are you crossing the threshold? Changing permanent establishment and other nexus rules

Session 3 of 4

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Join EY as it hosts a four-part webcast series “Advancing in a global tax environment in flux”. These sessions will highlight the challenges of managing tax risk in the current, continuously evolving, international tax landscape.

During these webcasts, our panelists will provide a holistic perspective, including practical insights for business, on the consequences of widespread BEPS implementation, the fundamental geo-political developments, such as Brexit and US Tax Reform, and rapid changes in the way tax authorities administer tax and co-operate with each other.

Panelists will focus on the key areas of impact: transparency, controversy and taxation by source countries through permanent establishments and similar nexus rules. The series will conclude with an overview of “not to forget” actions for 2017 and an overall perspective that will help make a good start in 2018.

During session 3, panelists will discuss the latest developments in the area of permanent establishments (PEs) and profit attribution, and its practical implications. Join our senior international tax professionals as they discuss:

  • How the implementation of changes to the PE provisions in the OECD model tax convention (MTC) arising from BEPS and integration of earlier guidance will impact your business
  • Challenges and the future of the revised OECD discussion draft on attribution of profits to PEs
  • The latest developments in the area of digitalization and digital PEs

The complete series and topics to be covered is set out below.

On-demand replays of webcasts will normally be available within 48 hours of original webcast.


EY - Ronald van den Brekel

Ronald van den Brekel


Ronald van den Brekel is the EY Europe, Middle East, India and Africa (EMEIA) transfer pricing leader. 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 more than 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 - Rajendra Nayak

Rajendra Nayak


Rajendra Nayak (Rajen) is a partner in the International Tax Services practice of Ernst & Young LLP, based in India. Rajen has nearly 20 years of experience in providing tax services. He has considerable experience in advising companies on taxation of cross-border transactions, transfer pricing planning, documentation & controversy management and assisting companies in international tax planning. He is actively involved in advising multi-national groups on the impact of BEPS on their structures.

Rajen is a Chartered Accountant from India and holds a Master’s degree in international taxation from the Regent University School of Law, USA. He is based in Bangalore, India.

EY - 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 - Channing Flynn

Channing Flynn


Channing Flynn is the EY Global Leader for Digital Tax and is based out of Silicon Valley in the United States. As the EY Global Technology Tax Sector Leader, he addresses the unique tax issues facing our largest technology clients.

During his 19 years with the firm, Channing has served clients with cross-border tax planning, including restructurings, M&A, supply chain transition, transfer pricing, US GAAP presentation of tax matters, IP alignment, IRS audit and procedural issues. His clients range from start-up companies to Fortune 100 multi-nationals as well as the full range of non-US multinationals operating in the US and globally.


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 is currently leading the BEPS desk in the 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, Jano 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.