Permanent Establishments

Master the post BEPS Permanent Establishment concept and the principles of profit attribution

As jurisdictions take coordinated and unilateral measures to tackle base erosion and profit shifting, the concept of Permanent Establishments (hereinafter “PEs”) becomes more relevant than ever.

Because the tax liability of an enterprise in a jurisdiction is oftentimes dependent on the existence of a PE, tax professionals need to be fully equipped with specialized knowledge to avoid unintended consequences.

This project is therefore aimed at providing you with a comprehensive online training on the evolving PE concept and corresponding profit attribution.

We draw from numerous case studies to ensure that you also learn how to apply the current approaches in your own practice.

By the end of this online course, you will be able to:

  • Review operating models for PE risk
  • Understand current approaches related to the attribution of profits to PEs
  • Understand interaction with transfer pricing
  • Apply the principles for profit attribution in your own practice


Featuring insights from:

Dr. Vikram Chand
Executive Director, Tax Policy Center,
University of Lausanne
Stefaan De Baets
Senior Counsel,
Pitambar Das
Additional Commissioner of Income Tax,
Government of India
Davide Anghileri
PhD Researcher,
University of Lausanne
Piotr Drobnik
Tax Manager,
Braxter Healthcare SA

Want access to all sessions?

Become a Member