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Permanent Establishments - Revisited

Published on 05 Mar 2015 | Took place at Greenwoods & Herbert Smith Freehills, Perth, WA

Determining whether you have a PE in a country continues to be a significant area of interest. While recent attention has been given to the challenge of identifying PE’s in the digital economy, there remains many questions as to when a PE exists in the old economy.

This event examined recent ATO ID 2014/29 relating to construction activities, consider the history to Article 5 of the Model treaty, BEPS Action 7 and attribution issues for PE’s.

Individual sessions

Permanent establishments - Revisited

Author(s):  Mark CEGLINSKI

This presentation covers:

  • why are we looking at this?
  • ATO ID – factual outline
  • OECD model tax convention – background, history and updates
  • review of the Australia/Japan convention
  • Action 7 BEPS Action Plan
  • PE attribution rules.
Materials from this session: