presents
Permanent Establishments and Taxation of Business Profits post BEPS
Permanent Establishments and Taxation of Business Profits Post BEPS
Join us for a comprehensive online event addressing 
core aspects of taxation of business profits in a post BEPS era
May 14
Online
Why Attend?
As countries and international organizations introduce measures to ensure enterprises pay their fair share of tax, companies which perform procurement, warehousing, sales and distribution across jurisdictions, and in particular digitalized businesses need to review their operating models for PE risk and address the issue of profit attribution.
We have invited Dr. Vikram Chand from University of Lausanne and Stefaan de Baets from PwC to provide us with their insights on PEs in a post BEPS era and attribution of profits thereof.
Meet the Speakers

Dr. Vikram Chand

Executive Director

Tax Policy Center
University of Lausanne


Stefaan De Baets

Senior Counsel

PricewaterhouseCoopers
Transfer Pricing

Donal O'Connell

Managing Director
IP Specialist
Adjunct Professor

Karen Holste

Independent Tax Advisor
Tax Litigation


Radomir Graj

Founder of Taxjobz
Senior Tax Manager at PepsiCo
Head of EMEA Tax

John Dar

CEO of Intercompany Software
Transfer Pricing


Barry Larking

Donal O'Connell


Donal is the Managing Director of Chawton Innovation Services, a company offering consultancy, education and software solutions in the areas of innovation and intellectual property management.

In the past years, his client base has included leading universities, global IP service providers, IP Firms, global telecoms companies, a compliance firm, global chemical companies, a global food and beverages company, a global heavy engineering company, one of the big four, and a variety of SMEs.





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Barry Larking

Karen Holste


Karen has worked with tax advisory and tax litigation for more than 20 years, both with the Danish National Tax Tribunal, with Big 4 companies and as an in-house CIT Lead and Legal TP responsible in private companies, both smaller growth companies and some of the biggest Danish companies, all working globally. Karen has a background as an attorney, thus using her legal skills when acting as an advisor. 

The systematic approach is reflected in the strategies planned with the clients when securing the tax risk position going forward. Currently, Karen is working to establish new methods and principles for aligning the work prepared by external tax advisors with the core business lines within the company group. This includes technical systems to support and manage tax risks and the tax litigation processes cross border to secure cross group alignment on tax audit management.

Barry Larking

Radomir Graj


Radomir is a seasoned tax professional with substantial in-house tax-legal experience in direct and indirect taxes, tax structuring and strategy, tax accounting, transfer pricing policies and documentation, tax compliance and financial reporting.

He is the founder of Tax jobz.com, a job board matching tax professionals and multinational corporations and professional firms across jurisdictions, including the US, UK and Switzerland. 

Taxjobz network reaches more than 100,000 tax professionals from Linkedin groups Tax Professionals and Tax Opportunities - Taxjobz.com and is the fastest growing job board for tax professionals.

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Barry Larking

John Farooque Dar

John is the co-founder and CEO of Intercompany Software, a solution which offers a new way to manage transfer pricing in medium and large groups with significant cross-border, intercompany trade between group companies. 

Previously, he served as TP lead in financial services for EY and KPMG in Denmark. He is focused on TP software and automation and helps companies execute their transfer pricing policies in a smarter, faster and more accurate way.





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Agenda
Session 1
Taxation of business profits and PEs
Session 1 of this event features Dr. Vikram Chand with his take on long term policy solutions for taxing digitalized businesses models.
 

 This is what the session will cover:
  •  Taxation of business profits and Permanent Establishments under the current tax treaty policy framework
  •  Taxing Digitalized Businesses: Turnover Taxes and Digital PEs in Tax Treaties
  •  Profit Attribution to Permanent Establishments 
  •  Shared Taxing Rights and Rethinking Nexus and Profit Allocation Rules
Session 2
Panel Discussion | Q&A
Session 2 includes a panel featuring Dr. Vikram Chand and Stefaan de Baets discussing core issues arising in the Attribution of Profits to PEs and the concept of Digital PEs.

This is what the discussion will cover:

  •   BEPS Action 7: tackling the artificial avoidance of PE status through commissionnaire or dependent agent arrangements and activity exceptions - e.g. preparatory activities
  •   European Commission’s directive on the taxation of digital PEs
  •   OECD's Interim Report the context of digital PEs
  •   OECD's Additional Guidance on the Attribution of Profits to PEs
  •   The Authorised OECD Approach for Profit Attribution 
    FAQ
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