Corporate Tax Club 1

Determining whether you have a PE in a country continues to be a significant area of interest. While recent attention has been given to the challenge of identifying PE's in the digital economy, there remains many questions as to when a PE exists in the old economy. This session will examine recent ATO ID 2014/29 relating to construction activities, consider the history to Article 5 of the Model treaty, BEPS Action 7 and attribution issues for PE's.