2019 Lectureship Series


Permanent Establishment in the 21st Century


 Guest Lecturer:

Jonathan Schwarz BA, LLB (Witwatersrand), LLM (UC Berkeley), FTII
Temple Tax Chambers, London, UK


Lectureship Dates |  Registration Fees  |  Schedule  |  Speaker Bio


Online registration is now closed.
Please contact ifacanada@ctf.ca with any questions!

Meaning of PE
The definition of permanent establishment in tax treaties has undergone the most significant change in its more than 100-year history. This seminar examines the new definitions in the OECD and UN model treaties, the impact of the BEPS MLI on treaty practice and their implications for cross-border business.
The 2017 OECD Commentary to the model treaty incorporates the 25 issues examined in the pre-BEPS consultation on the meaning of permanent establishment. The utility of the revamped Commentary will be analysed.
Recent case law around the world will be discussed to indicate both administrative and judicial approaches to existing treaty definitions.
Attribution of profits
The Authorised OECD Approach to attribution of permanent establishment profits is now in its 10th year of adoption. The seminar will examine treaty practice in relation to the AOA, the 2010 revised OECD model article 7 and recent case law on profit attribution as well as OECD work post-BEPS on this issue.
Unilateral measures
Unilateral approaches as exemplified by the UK diverted profits tax will be discussed.

  Schedule Vancouver, Calgary, Toronto

  7:30 AM – 8:30 AM

   Registration and Breakfast

  8:30 AM – 12:30 PM

   Lectureship: Permanent Establishment in the 21st Century

 Schedule | Montreal

 9:30 AM – 10:00 AM


 10:00 AM – 2:30 PM

   Lectureship: Permanent Establishment in the 21st Century

  Nationwide Lectureship Dates   


 Monday, February 11, 2019

Pan Pacific Vancouver
300 – 999 Canada Place, Vancouver V6C 3B5
Room: Oceanview Suite 5


 Tuesday, February 12, 2019
Calgary Marriott Downtown Hotel
110 9th Avenue SE, Calgary T5G 5A6
Room: Acadia AB (2nd floor)


 Thursday, February 14, 2019
Pantages Hotel Downtown Toronto
200 Victoria Street, Toronto M5B 1V8|
Room: Rehearsal Hall 3


 Friday, February 15, 2019
DoubleTree by Hilton Montreal (formerly Hyatt Regency)
1255 Jeanne-Mance Street, Montreal H5B 1E5
Room: Symphonie 3



Email IFACanada@ctf.ca with any questions


Registration Fees  
Provincial taxes apply to the listed registration fees
  Member Non-Member Registration + Membership Special 1
$275 $290
$90 $150
Young Member 2
Jeune membre
$90 $150


$10 $25 $80

Special: Registration + 2019 IFA membership / Spéciale: Inscription + adhésion 2019 de l’IFA


2 YM/JM: Young Members are those 29 and under on January 1, 2019. New members, please provide your date of birth to IFACanada@ctf.ca



1,2  Special Offers valid for new members only / Offre spéciale valuable pour les nouveaux membres seulement


Membership: You can view membership rates or renew your membership by downloading the PDF registration form, or online by clicking here.


Provincial tax rates

Alberta: 5% GST

British Columbia: 5% GST

Quebec: 9.975% QST and 5% GST

Ontario: 13% HST