CFE Forum 2011

The annual Forum of the Confédération Fiscale Européenne (CFE) on 'Permanent Establishment in Direct and Indirect Tax' will take place on Thursday 7 April 2011 from 9:00 hrs to 17:15 hrs at the Representation of Saxony-Anhalt to the European Union, Boulevard Saint Michel 80, 1040 Brussels. 

Permanent Establishment is a vital concept in international taxation. While for direct taxes, it is mainly defined by the OECD Model Convention, the European VAT Directive and its implementing Regulation provide an EU-wide approach for VAT.

Difficulties arise as terminology and definitions in indirect and direct tax diverge. Moreover, countries have implemented and interpreted the EU and OECD rules in a different way, impacting on issues like cross-border reorganisations, transfer pricing, taxation of dividends and interest and royalties, tax residence, temporary and permanent transfer of assets, place of supply and VAT liability.

In both direct and indirect tax, the concept of Permanent Establishment has undergone very recent changes: The 2010 changes to the OECD Model Convention and Commentary, and in particular the new Art. 7, will be adopted in national law, as speakers from the Netherlands and Germany will report. The effect of the new definition on treaties with other countries will also be considered.

In indirect tax, the discussion will deal with the practical consequences of the adoption of the Regulation implementing the EU VAT Directive in January 2011.

Please find attached the programme, registration form which needs to be returned to the CFE Brussels office by e-mail or by fax before Friday 1 April 2011 and a map.

More information on http://www.cfe-eutax.org/node/2568.