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

 



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

   Registration

 10:00 AM - 2:30 PM

   Lectureship: Permanent Establishment in the 21st Century




  Nationwide Lectureship Dates   


  VANCOUVER

 Monday, February 11, 2019
Pan Pacific Vancouver
300 - 999 Canada Place, Vancouver V6C 3B5

  CALGARY

 Tuesday, February 12, 2019
Calgary Marriott Downtown Hotel
110 9th Avenue SE, Calgary T5G 5A6

  TORONTO

 Thursday, February 14, 2019
Pantages Hotel Downtown Toronto
200 Victoria Street, Toronto M5B 1V8

  MONTREAL

 Friday, February 15, 2019
Hyatt Regency Montreal
1255 Jeanne-Mance Street, Montreal H5B 1E5

 

 

Email This email address is being protected from spambots. You need JavaScript enabled to view it. with any questions

 

Registration Fees  
Provincial taxes apply to the listed registration fees
  Member Non-Member Registration + Membership Special 1
Regular
Régulier
$190
$275 $290
Prof./Govt
Prof./Gouv
$60
$90 $150
Young Member 2
Jeune membre
$60
$90 $150

Student
Étudiant

$10 $25 $80
 


1
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 This email address is being protected from spambots. You need JavaScript enabled to view it.

 

 

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