Tax 101 Series: Permanent Establishment, Tax Treaties, Double Tax Agreements

hide mobile image
default image
19 May 2021, Wednesday

01.00 - 02.30PM

Details/ Promotion:
Please click here for more details and here to register.
Please refer to organiser’s webpage here.
Share the Event:

Programme Synopsis

In the Christmas Tree Plantation Ruling: the Danish Tax Board concluded that foreign enterprise is deemed to have a fixed place permanent establishment even in absence of employees or dependent agents at the place of business in Denmark.

This session discusses the concept of PE and its interplay between domestic tax law, tax treaties and double tax agreements. Most of the time, many would think, the PE issues arising from a simple and straight forward transaction is low-risk". The "Christmas Tree Plantation Ruling" provides excellent insights into many exciting and intricate facets of (interpretation) PE. "Tax planning is all about long-term thinking (tax certainty)" – hence, an understanding of your fundamental tax rights (entitlements) will allow you to manage and mitigate your tax risk with confidence.

This session is a mix of practical experience and academic knowledge.

Programme Outline

  1. Introduction to the Singapore law of treaties & DTA
  2. Meaning of PE: Fixed place of business v 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

About the Presenter(s)/ Trainer(s)

event image

Mr Kevin Matthaios Lee
Advisory Consultant
JPL Wong Tax Services Pte Ltd
Accredited Tax Practitioner (Income Tax)

Kevin, a business finance professional, is also a Subject-Matter Expert (SME) in the tax practise of a mid-tier professional services firm, while simultaneously holding a position as a trainer/facilitator where he shares his insights on the global issue in FRS, political science and economics and international business law. He has been a speaker at various seminars, and network (exclusive) events, inter alia, Wolters Kluwer (CCH), ISCA, CIMA and ACCA. 


Upcoming Events
Tax Articles and Webinars On-demand
Tax News
Taxlogues (members-only access)
The Region's Tax

Please click here for speaking opportunities at SIATP's (now referred to as SCTP) events.


Benefits and Privileges of Accreditation
Accreditation Criteria
Membership Fees
Apply Now

Please click here for possible publication of your article.

Privacy & Data Protection Policy | Terms of Use | Copyright © 2021 Singapore Chartered Tax Professionals Limited

This site is best viewed in Google Chrome and Mozilla Firefox. Please use the print-friendly icon on the left for optimum prints.

facebook icon
linkin icon
email icon
print icon