2010 IFA Travelling Lectureship

2010
IFA Travelling Lectureship

The Definition of Permanent Establishment: Eroding or Evolving?

Lecturers
Brian Arnold, Tax Consultant
Jacques Sasseville, OECD

[Course Outline]   [Dates & Locations]   [Speaker] [Registration]

The topic of the 2010 IFA Travelling Lectureship is the concept of permanent establishment (PE) in Canadian tax law and treaties and in the model tax treaties of the OECD and the United Nations.  The concept of a PE plays a central role in the taxation of business profits under tax treaties. The definition of a PE is the subject of ongoing work by the OECD and the United Nations.  It has also been the focus of several important Canadian and foreigh court cases.  Moreover, the addtion of Article V(9) of the Canada-United States treaty represents an important development in Canadian tax treaty policy.

Despite the importance of the definition of a PE, several difficulties with respect to the interpretation and application of the definition continue to concern tax practitioners and tax officials.  The seminar, led by Brian Arnold, a tax consultant, and Jacques Sasseville of the OECD, will explore the policy and technical issues of the definition of a PE and will provide participants with insights into the interpretation and application of that definition in Canadian tax treaties.

Course Outline 

The Definition of Permanent Establishment: Eroding or Evolving?

The seminar will be interactive in nature, combining lectures, case studies, and discussion.  Participants are actively encouraged to engage in the discussions.  In order to facilitat participation, each participant will be provided with course materials serval weeks before the seminar.  These materials will include the General Report, "Is ther a permanent establishment?" from the 2009 IFA Congress, selected PE provisions from Canadian tax treaties, the Commentary on Article 5 of the OECD Model Convention, selected cases dealing with PEs, and several case studies.  

Dates and Locations

ACCOMMODATION: Out of town participants should make their own hotel reservations.

Seminar Leaders

Brian J. Arnold
 Brian J. Arnold is a professor of tax law emeritus and a tax consultant.  He has written several books and numerous articles on tax matters.  He teaches international tax at Harvard Law School and the Universities of Melbourne and Sydney.  From 2000 to 2007 he was a member of the Permanent Scientific Committee of IFA.  He has also been a consultant to several countries and the OECD on tax issues.

Jacques Sasseville
Jacques Sasseville is Head of the Tax Treaty Unit, Centre for Tax Policy and Administration at the Organization for Economic Co-operation and Development (OECD).  In this capacity he is involved in all of the work related to the OECD Model Treaty.  He was the co-general reporter on the topic of permanent establishments for the 2009 Vancouver IFA Congress.  He is a member of the Permanent Scientific Committee of IFA and a frequent speaker and author on the subject of tax treaties.

Registration

Registration form 

Please complete the registration form and send with payment by mail, email (office@ifacanada.org), or fax (613-531-0626) to the IFA Canada Office. The lectureship materials will be stored on the website, and only those who are registerd will be able to access and download the material for reference.  Registrants will be notified by email how to access the materials.