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The unintended creation of Permanent Establishment (PE) is a continuous and growing concern for corporations with overseas operations. One of the biggest challenge now includes, globally mobile employees potentially creating PE risks. Many discover that they have inevitably created a PE which puts them in a country’s tax net. Hence, understanding the essence of the PE concept, is key in the management of PE exposure of your organisation.
Additionally, there will be coverage on the impact of an important BEPS’s action plan: to develop changes to the definition of PE to prevent the artificial avoidance of PE status, including through the use of commissionaire arrangements and the specific activity exemptions.
This practical workshop will enable you to grasp the framework and essentials of PE as well as their impacts on tax planning, through a combination of numerous case studies and interactive discussions.
At the end of this programme, you will be able to:
Overview of PE
Recent Tax Cases and Case Studies
Overview of Countries’ MLI Preference on PE Provisions in the Tax Treaties
How do Companies Manage PE Risk?
Looking Forward – BEPS 2.0 and the Relevance of Physical Nexus
Chester Wee, Partner and ASEAN International Corporate Tax Advisory Leader, Ernst & Young Singapore
Chester has 20 years of experience in advising on cross-border tax issues, managing tax controversy as well as handling tax compliance and reporting – in both inbound and outbound investments.
Chester is experienced in tax structuring, permanent establishment risk management and tax controversy and dispute resolution.
He has deep knowledge in reviewing holding structures and operating models; managing tax residence issues; identifying and managing withholding tax issues and permanent establishment risks; and advising on intellectual property (IP) strategies and migration, and tax efficient repatriation of profits and cross-border financing.
Chester completed the Advanced Tax Programme at the Tax Academy of Singapore. He earned his bachelor’s degree in Accountancy from Nanyang Technological University.