WebinarTax & Accounting

Inbound investment: Cross border transaction into Singapore - PE

16 August 2022 | 9:30-11:00 AM MYT
Law of tax treaties: Double tax agreements & meaning of permanent establishment (“PE here, PE there, PE everywhere?”)

Are you certain that your PE avoidance strategies work effectively on the fast-changing and increasingly restrictive practices of tax administrations in different countries? When you struggle or not able to answer the above questions with a firm ‘yes’, or when the CFO, CEO and board show little awareness of the risks, these are all signs of you may find yourselves susceptible to PE-related risks.

This session discusses the concept of PE and its interplay between Singapore tax law, tax treaties and double tax agreements. An understanding of your business’s fundamental cross-border (potential) risks will allow you to manage your tax risk with confidence.

The law of international taxation is used in this seminar to describe the rules and principles that together form how IRAS asserts and limits its jurisdiction to tax cross-border flows of income. However, you should be aware that there is no universally accepted view as to the precise nature of international tax law, and there is even a view that there is no overarching international tax regime. That there are competing views in this area is of little surprise. As you will discover, taxation is a highly controversial and politically driven area of study, and that makes it even more exciting and exciting. This program is a mix of practical experience and academic knowledge.


  1. Introduction to the Singapore law of treaties & DTA
  2. Meaning of PE: Fixed place of business vs a fixed place PE
  3. Mere 66-day activity in the Source State gives rise to PE?
  4. Mere storage of construction material give rise to PE?
  5. Exploratory case study – “the Christmas Tree Plantation Ruling”
  6. Q&A


Kevin Lea, Business finance professional and subject-matter expert in the tax practice.

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