Fundamental Concept Of Permanent Establishment

Fundamental Concept Of Permanent Establishment

Tuesday, 17 March 2015

Start at 09.00 am finish at 05.00 pm

Training Center, Menara Satu Sentra Kelapa Gading

Rp. 3.000.000,-
Including: Workshop kit, Updated hardcopy material, Certificates, Coffee break & meals, Library access, and others modern supporting facility


The question arises from non-resident companies in carrying on business activities in the source country, whether to carry on business through a Permanent Establishment (PE)? The answer to this question might be “yes” and “no”. If so, for those who want to carry on their business activities through a fixed place of business, dependent or independent agents, and hope can certainly carry on their business activities in the source country. Unless, if non-resident intended to avoid administrative tax burden in source country or in other words, not subject to domestic taxation therein.

However, to determine the existence of a PE, it needs to consider the relevant factors associated with the time threshold or the activity undertaken in the source country. Not to mention the existence of the declaration of the G20 with the OECD, which include the issue of PE in 15 Plan of Action on the issue of the Base Erosion and Profit Shifting (BEPS Action Plan). BEPS Action Plan 1, the OECD and the G20 will focus on addressing issues in PE that was developing in the information technology industry and digital communications. Then BEPS Action Plan 7, the OECD and the G20 will lower the threshold of PE to provide more taxing rights to the source country.

Above it, with this valuable seminar, you will capture clearly concept of PE in performing cross border transactions between the companies in treaty partner.  In this valuable seminar, you will capture clearly concept of PE in performing cross border transactions between the companies in treaty partner.

With material that we have to offer the following:

Introduction: The Concept of PE:

  • The taxpayer’s physical presence: The “Place of Business Test”;
  • Physical presence at a specific place: The “location test”;
  • The Right to use the place of business: The “right of use test”;
  • The “right of use test” for profit-sharing arrangements;
  • The “right of use test” and arm’s length business connections;
  • Indirect evidence of a right of use to a place of business.

The Functionality of the PE:

  • Business activities excluded in the treaties;
  • The domestic – law aspect: Income-generating activities distinguished from business in the treaties;
  • The business connection test;
  • The “force of attraction principle” of the UN Model Tax Treaty.

Agency Permanent Establishments
PE and the Digital Economy
PE Issues Arising from Centralized Tax Models
Tax Planning Optimization in the context of Permanent Establishment.


  1. With the existence of fundamental analysis of the concept of permanent establishment, participants can gain permanent allocation establishment which has been the debate of academics, practitioners, tax authorities and international organizations
  2. Through Functional Analysis of permanent establishment, participants have the power to deal with the findings of the tax authorities
  3.  Guiding participants to not get stuck in the double taxation
  4. With the existence of explanation of the current issue of the permanent establishment, participants can identify the elements of permanent establishment so they can decide whether a business including permanent establishment or not.

– Yusuf W. Ngantung, Senior Manager of International Tax/Transfer Pricing Services
– Ganda Christian Tobing, Senior Manager of Research and Training Services

Who should attend:

The seminar is valuable for Corporate tax Adviser; International tax expert and executives; Tax professional and controller; Tax attorneys; Accountants; and Anyone else who have responsibilities on Taxation.

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