Register to our Transfer Pricing Breakfast in May 2018 - Tax and Legal blog

Transfer Pricing Breakfast_May18_Blog

Since the initiation of the Global Tax Reset there is an increased focus on Permanent Establishments (PEs). Now the OECD has published its Additional Guidance on the Attribution of Profits to PEs and the European Commission (EU) issued a proposal to tax digital services via PEs, we would like to give you a pragmatic update on the developments around PEs in recent years and how these changes might impact your business.

Register to our upcoming Transfer Pricing Breakfasts that will take place on Wednesday, 23 May 2018 in Geneva and on Thursday, 24 May 2018 in Zurich.

As part of these breakfasts, our speakers will discuss:

  • Relevant developments around PEs in recent years and the anticipated impact of the new OECD Model Tax Convention
  • Deloitte's view on the OECD its Additional Guidance on the Attribution of Profits to PEs and the EU its proposal to tax digital services via PEs.
  • Our practical experience on how to deal with Commissionaire Arrangements in relation to the developments around PEs
  • Possibilities to align your business model to cope with the new challenges
  • Aspects of interesting recent TP cases and how these will impact your work. 

Your value in participating

  • Understand the developments in relation to PEs that occurred in recent years and how these can impact your business through the applicable local tax treaties
  • Get Deloitte’s view on the Additional Guidance on the Attribution of Profits to PEs as recently published by the OECD and the EU its proposal to tax digital services via PEs
  • Be informed about how to deal with Commissionaire Arrangements in the future and learn from our practical experiences in this respect
  • Gain insight knowledge about recent international TP cases and how these impact the TP practice

Interested to join us?

For more information about the agenda and to register, please contact Daniela Flühler.  

Raoul Stocker_BLOG

Raoul Stocker - Partner, Business Tax Leader Zurich

Raoul Stocker is a tax partner with more than 15 years’ experience specifically in international tax litigation such as mutual agreement procedures and advanced pricing agreements. His focus lies on corporate tax planning, cross-border structuring of corporate transactions and businesses, transfer pricing as well as taxation of financial institutions. Raoul is also a lecturer of transfer pricing and tax law at the University of St. Gallen.

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Habermacher_Blog

Hans Rudolf Habermacher - Partner, Transfer Pricing Leader Switzerland

Hans Rudolf has over 17 years’ of experience in advising clients in Transfer Pricing concepts. He successfully engages with MNCs in various industries in the planning, implementation, documentation & defence of TP concepts. Further he has significant experience in the design and implementation of principal & licensing structures. He is also highly successful in filing and negotiating bilateral APA's (Advanced Pricing Agreements) and mitigating double taxation issues through MAP procedures.

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