Law of tax treaties: Double tax agreements & meaning of permanent establishment (“PE here, PE there, PE everywhere?”).
Are you confident that your PE avoidance strategies work effectively on tax administrations' fast-changing and increasingly restrictive practices in different countries? Whether you struggle or not to answer the above questions with a firm ‘yes’ or whether the CFO, CEO and board show little awareness of the risks; these are all signs that 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. Understanding 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 income flows. However, you should be aware that there is no universally accepted view of the precise nature of international tax law, and there is even a view that there is no overarching international tax regime.
What you’ll learn:
- Introduction to the Singapore law of treaties & DTA
- Meaning of PE: Fixed place of business v a fixed place PE
- Mere 66-day activity in the Source State gives rise to PE?
- Mere storage of construction material gives rise to PE?
- Exploratory case study – the Christmas Tree Plantation Ruling
Who should attend: Both tax and non-tax trained junior executives or anyone interested in understanding the impacts of international tax/cross-border transactions on their line of work.
Presenter: Kevin Lee, a business finance professional and subject-matter expert in the tax practice.