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