The Attribution of Profits to Permanent Establishments – Forthcoming Transfer Pricing Webinar

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In a forthcoming webinar from BNA International, taking place 30 June 2011, a panel of leading transfer pricing experts will provide guidance on the latest Transfer Pricing rules (and approaches which could be taken) in the UK, US and India regarding the attribution of profits to Permanent Establishments.

In a forthcoming webinar from BNA International, taking place 30 June 2011, a panel of leading transfer pricing experts will provide guidance on the latest Transfer Pricing rules (and approaches which could be taken) in the UK, US and India regarding the attribution of profits to Permanent Establishments.

In 60-90 minutes, the panel in The Attribution of Profits to Permanent Establishments will examine the following key issues from the Indian, UK and US perspectives:

  • The "Authorised OECD Approach" - to what extent is this reference to the functions, assets and risks of the permanent establishment reflected in local tax legislation and guidance?
  • The OECD has also proposed reference to any "significant people functions" performed by the permanent establishment in order to determine the profit which should be attributed to it. To what extent has this approach been adopted by each tax administration for the attribution of profits to "dependent agent" permanent establishments, as might be created by sales and marketing subsidiaries for example?
  • The revised Article 7 of the OECD Model Convention implies that interest and royalty expense should be recognised in the attribution of profit to a permanent establishment. Do local legislation and guidance now reflect this approach?
  • How is capital attributed to a permanent establishment, both as a matter of domestic law and tax treaty practice? What is the approach specifically to financial institutions?
  • How are profits attributed to a foreign permanent establishment of a locally resident company for double tax relief purposes?
  • Certain transfer pricing methods, such as the Berry Ratio, can suggest a very high profit for a permanent establishment. Which methods are favoured for the attribution of profits to permanent establishments and does this vary between fixed place of business and dependent agent permanent establishments?

Speakers include:

  • Danny Beeton

Head of Transfer Pricing Economics, Freshfields Bruckhaus Deringer, (UK)

  • Murray Clayson

Tax Partner, Freshfields Bruckhaus Deringer, London, (UK)

  • Rahul Mitra

Partner & Head of Transfer Pricing, PricewaterhouseCoopers, India

  • Len Schneidman

Managing Director at the Boston office of WTAS (US)

The speakers are all experienced transfer pricing professionals. As time will be set aside for questions, the webinar gives listeners the opportunity to apply the panel’s expertise and knowledge to their own context. Questions can be emailed in and the panel will answer as many questions as possible.

A single registration allows all colleagues per site to listen in and participate.

Attribution of Profits to Permanent Establishments will take place Thursday 30th June at 3pm UK time.

To register for this webinar, visit http://www.bnai.com/shop/details1.aspx?id=296 or call + 44 (0)20 7847 5801.

The per site fee is £155.00/ $249.00/ €170.00.

About BNA International

BNA International helps companies and their advisers operate successfully in global business. It provides international information for international business. Use BNA International's services to obtain accurate news and detailed analysis of worldwide legal developments in the following core areas:

  • International tax
  • IP, communications and technology
  • Business and finance

In addition, as the London-based subsidiary of BNA, BNA International also handles enquiries and provides support for the full range of BNA's products outside North America. See http://www.bna.com to view services from our parent company, BNA.

Media Contact (Outside North America):

Charlotte Berry
+ 44 (0)20 7847 5805

Media Contact (North America):

Mark Carrington
+1 703 341 5880

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Charlotte Berry
BNA International
+44 (0)20 7847 5805
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