BorderCrossings ... with Ernst & Young's transfer pricing and tax professionals
Permanent establishments in the global economy: international tax, human capital, transfer pricing
Transfer pricing touches nearly every area of your multinational operations, making it one of your key tax challenges and concerns. Increasingly well-staffed tax authorities are applying more sophisticated and sweeping transfer pricing tools, placing greater demands on you to document and defend your transfer pricing in more and more countries. To help you stay informed and able to adopt a more proactive stance in developing and defending your transfer pricing policies and practices, Ernst & Young is pleased to bring you this sixth installment of BorderCrossings – our monthly webcast series devoted to transfer pricing and related tax issues.
Permanent establishments in the global economy: international tax, human capital and transfer pricing considerations
Changes in international tax treaties and their interpretation mean that it is easier than ever to create a permanent establishment (PE). Consequently, MNEs need to be more concerned with determining the taxable profit to report in a PE, both to accurately report income in acknowledged PEs, and to quantify the risk of tax authorities asserting new PEs. This webcast will continue from where the 28 June 2011 webcast on “Attribution of profits to a permanent establishment” left off. The speakers will address the following questions:
- What is a “Dependent Agent PE”?
- What is a “Service PE”?
- Impact of the Canada-US Tax Treaty and Recent Technical Interpretations
- How does your transfer pricing policy impact the creation of a PE?
- What are the implications of creating a PE on personal income tax obligations of an employee?
- What are the implications of creating a PE on the employer’s obligation to withhold and remit payroll taxes?
During this live, interactive webcast, you will have the opportunity to ask questions through the website and the panelists will answer as many of your questions as time permits.
This program will be of interest to vice presidents/directors of tax/international tax/transfer pricing, directors of finance, CFOs, international tax managers and tax accountants looking for the latest practical information and planning ideas to support their global business initiatives. We hope you will be able to join us.
Cedric Bernardeau, Ernst & Young LLP (US), Transfer Pricing
Mohamed Jabir, Ernst & Young LLP (US), Human Capital
Mark Kaplan, Ernst & Young LLP (Canada), International Tax Services
Fred O’Riordan, Ernst & Young LLP (Canada), National Advisor, Tax Services
Save the dates for upcoming BorderCrossings webcasts:
1:00–2:15 p.m. EDT New York/Toronto; 10:00–11:15 a.m. PDT Los Angeles/Vancouver
- Tuesday, 23 August
- Tuesday, 27 September