In operating across borders there is the risk of creating a Permanent Establishment (PE). Sometimes MNEs go a long way as to make sure that they do not run into an unintended PE risk and sometimes MNEs are considering and are effectively deploying a business strategy in having an intended PE in certain locations.
This workshop will cover the current developments, how it may lead to a PE and how to manage PE impact on your organisation. It will also address relevant international tax highlights from Budget 2023 if any, and the impact of the relevant sanctioned BEPS 2.0 considerations regarding the allocation of taxing rights under Pillar One and the minimum tax rate considerations under Pillar Two vis-a-vis the relevance of the PE exposure.
This practical workshop will enable you to grasp the framework and essentials of PE as well as their impacts on tax planning, through a combination of numerous case studies and interactive discussions.
A Highlight of Key Areas:
Overview of PE
- What is a PE
- Types of PE
- Singapore’s domestic definition of PE in Section 2 of the Singapore Income Tax Act
- Definition of PE provided in Article of the OECD and UN Model Conventions
Recent Tax Cases and Case studies
- PE tax considerations and cases –
- Online business models
- Construction activities
- Sales & marketing activities
- Recurring nature of activities
How do MNEs Manage PE Risk?
- Limited Risk Distributors (LRD) model
- PE blocker structures
- Personal Employment Companies (PEC)
- Monitor, manage business travellers
International Tax Considerations & Budget 2023 Highlights
- Current state of play BEPS 2.0
- Interplay rules Pillar One and Pillar Two and PE concept
Q&A Session