2010 IFA Travelling Lectureship

IFA Travelling Lectureship

The Taxation of Business Profits: Fracture of the International Consensus?

Richard Vann, Challis Professor of Law, University of Sydney

[Course Outline]   [Dates & Locations]   [Speaker] [Registration]

The topic of the 2011 IFA Travelling Lectureship is the developing international tax law on attribution of profits to permanent establishments ((PEs) in the model tax treaty of the OECD and its impact (or lack thereof) on other Models such as the United Nations and on actual treaties. The focus is on the treaty interpretation issues rather than the transfer pricing analysis. The attribution  

Course Outline 

The Definition of Permanent Establishment: Eroding or Evolving?

 Registration and Refreshments 
 • role of the concept of permanent establishment in Canadian tax law and treaties and in model tax treaties


 Fixed Place of Business PEs
 • basic elements of the definition
 • examples in Article 5(2)
 • construction sites
 • cases
10:30-11:00  Break
11:00-11:30  Dependent Agent PEs
11:30-11:45  Exemption for Preparatory and Auxiliary Activities
 Services PEs
 • Article V(9) of the Canada-United States treaty
 • alternative services PE provision in the Commentary on Article 5
 • UN Model provisions

The seminar will be interactive in nature, combining lectures, case studies, and discussion.  Participants are actively encouraged to engage in the discussions.  In order to facilitat participation, each participant will be provided with course materials serval weeks before the seminar.  These materials will include the General Report, “Is ther a permanent establishment?” from the 2009 IFA Congress, selected PE provisions from Canadian tax treaties, the Commentary on Article 5 of the OECD Model Convention, selected cases dealing with PEs, and several case studies.  

Dates and Locations

 TORONTO        Monday March 8, 2010     Conservatory One, 16th floor
St. Andrew’s Conference Centre
150 King Street West 
 OTTAWA Tuesday March 9, 2010 

Quebec Suite
Fairmont Chateau Laurier
1 Rideau Street

 MONTREAL Wednesday March 10  Cartier I
Centre Mont-Royal
2200 Mansfield Street
 VANCOUVER Wednesday April 28, 2010  West Meeting Room 208 & 209
Vancouver Convention Centre
999 Canada Place 
 CALGARY  Friday April 30, 2010 Strand/Tivoli Room
Metropolitan Conference Centre
333 – 4 Avenue Southwest 

ACCOMMODATION: Out of town participants should make their own hotel reservations.

Seminar Leaders

Brian J. Arnold
B. Arnold Brian J. Arnold is a professor of tax law emeritus and a tax consultant.  He has written several books and numerous articles on tax matters.  He teaches international tax at Harvard Law School and the Universities of Melbourne and Sydney.  From 2000 to 2007 he was a member of the Permanent Scientific Committee of IFA.  He has also been a consultant to several countries and the OECD on tax issues.




Jacques Sasseville
 Jacques Sasseville is Head of the Tax Treaty Unit, Centre for Tax Policy and Administration at the Organization for Economic Co-operation and Development (OECD).  In this capacity he is involved in all of the work related to the OECD Model Treaty.  He was the co-general reporter on the topic of permanent establishments for the 2009 Vancouver IFA Congress.  He is a member of the Permanent Scientific Committee of IFA and a frequent speaker and author on the subject of tax treaties.




Registration form 

Please complete the registration form and send with payment by mail, email (office@ifacanada.org), or fax (613-531-0626) to the IFA Canada Office. The lectureship materials will be stored on the website, and only those who are registerd will be able to access and download the material for reference.  Registrants will be notified by email how to access the materials.