EMEA PE Webcast Series – Episode Four – VAT consequences of a corporate tax permanent establishment

Tuesday, 17 April 2018, 3.00 – 3.45 pm CET

After a short break, we are pleased to inform you that we will resume the PE Webcast Series, with Episode 4 – VAT consequences of a corporate tax permanent establishment.

In this webcast specialists from our international tax and VAT practice will compare the objectives and concepts of a corporate tax permanent establishment with a VAT fixed establishment (FE).

We will walk through practical examples to demonstrate the interaction of these rules, outlining the VAT consequences of creating a corporate tax PE, as well as the corporate tax position if you have a VAT FE.  As part of the discussion we will highlight trends in the application of PE and FE rules by tax authorities, leading in some cases to a blurring of the concepts.

You will have the chance to raise questions directly to our specialists.

Speakers for episode four will include:

  • Monica Cohen-Dumani – Partner, International Tax Services, EMEA ITS Leader – PwC Switzerland
  • Ine Lejeune – Partner Tax Policy, Dispute Resolution & Litigation – Law Square
  • Herman van Kesteren – Partner Indirect Taxes – PwC Netherlands

Registration Link

Complete the required registration fields and select “Submit”.
Once you have registered, you will receive the WebEx access details. The WebEx will be recorded and you will receive a link to the recording via e-mail after the event using the same details. There will be time for questions and answers with your speakers during the WebEx. Questions can also be sent in advance of the
WebEx session to the following email address: grasiele.neves@ch.pwc.com

We do hope that you will join us online!

Best regards,
Monica Cohen-Dumani

Contact

Monica Cohen-Dumani
Partner, EMEA ITS Central Cluster Leader
+41 58 792 97 18
monica.cohen.dumani@ch.pwc.com

Grasiele Teixeira Neves
International tax services
+41 58 792 98 25
grasiele.neves@ch.pwc.com

EMEA Webcast: EMEA ITS US Tax Reform Series – Practical Guidance for European Multinationals – Episode 4: State tax implications of federal tax reform

State tax implications of federal tax reform

Wednesday, 7 February 2018, 4.00 – 5.00 pm CET

While US tax reform is focused on measures at federal level, it will lead to a diverse and wide-ranging number of state tax implications as a result of how/whether states conform to the federal Internal Revenue Code provisions. There are accordingly a number of critical elements that have the potential to significantly affect state tax and financial statements, such as deemed repatriation toll charge; interest expense limitations; and the international provisions discussed on our previous calls, namely BEAT, GILTI and FDII.

Episode 4 of our webcast series will therefore look in more detail at the state tax implications, with particular focus on the international measures and the tax accounting implications.

We will be joined by our state tax and tax accounting specialists in order to provide an overview of the key areas you should be considering.

Please follow the link below to register for episode 4 and note that recordings will be available if you register and you cannot join the live session itself.

To register for Episode 4: Click Here

In case you were not able to join our previous episodes and would like to view the recording, find hereafter the required links (you will need to register to watch the recording):

Contact Us

Richard Brunt
Tel.+41 58 792 81 82
richard.brunt@ch.pwc.com

Grasiele Teixeira Neves
Tel.+41 58 792 98 25
grasiele.neves@ch.pwc.com

EMEA Webcast: How US Tax Reform impacts European Multinationals

Monday, 27 November 2017, 4.00 – 5.00 pm CET

As you may be aware, on 9 November 2017 the House Ways and Means Committee approved by party-line vote of 24 to 16 the ‘Tax Cuts and Jobs Act of 2017’ (HR 1) bill. On the same day, the Senate Finance Committee released a description of their proposals.

Both the HR 1 bill and Senate proposals call for lower business and individual tax rates and modernize the US international tax rules, with significant impacts on numerous sectors of the economy.

In this webcast PwC specialists will provide an update on the provisions, the latest on potential timing, and have a discussion on the practical implications of the US Tax Reform on non-US based multinationals.

Speakers for this webcast will include:

  • Monica Cohen-Dumani – Partner, International tax services, Central Cluster ITS Leader – PwC Switzerland
  • Tom Patten – US Tax Partner, PwC UK
  • Bernard Moens – US International Inbound Tax Services Leader, PwC New York
  • Christopher P. Kong – US Inbound Tax Leader, PwC
  • Scott McCandless – US Federal Tax Policy Services Partner

To register for the WebEx Session: Click Here 

Contact Us

Monica Cohen-Dumani
TLS Partner
+41 58 792 97 18
monica.cohen.dumani@ch.pwc.com

Stefan Schmid
TLS Partner
+41 58 792 44 82
stefan.schmid@ch.pwc.com

Martina Walt
TLS Partner
+41 58 792 68 84
martina.walt@ch.pwc.com

Policy on the move webcast: Time to get practical on tax

On Thursday, 2 November 2017, the US House of Representatives released a draft bill on US corporate tax reform. There are many significant proposals in the draft bill that would have an impact on investment into the US. While it’s the first official stage of the legislative process, and there could be several changes to the final legislation if enacted, its significance shouldn’t be underestimated. There is a very active dialogue ongoing with amendments and positions since its release already. For further details, please read the attached newsletter.

We do expect a draft bill also to be released by the Senate next week. This bill will be telling in terms of the process, as we will see how closely aligned the two houses are on the issues. As many elements are in flux at this stage, a more detailed newsletter will be prepared once the Senate releases its draft bill next week.

The US firm is hosting a client webcast on Monday, 6 November at 18:00 (CET). Details are below:

Register

Download Attachment 

PwC Switzerland will hold a webcast focused more directly towards a non-US audience after any Senate action as well.

Contact Us

Monica Cohen-Dumani
TLS Partner
+41 58 792 97 18
monica.cohen.dumani@ch.pwc.com

Stefan Schmid
TLS Partner
+41 58 792 44 82
stefan.schmid@ch.pwc.com

Martina Walt
TLS Partner
+41 58 792 68 84
martina.walt@ch.pwc.com

Pascal Bühler
TLS Partner
+1 646 471 1401
buehler.pascal@us.pwc.com

Michael Ruckstuhl
TLS Director
+41 58 792 14 94
michael.ruckstuhl@ch.pwc.com

EMEA PE Webcast Series – Episode Three – PE and Global Employee Mobility

Thursday, 14 September 2017, 3.00 – 3.45 pm CET

International businesses need a globally mobile workforce and while technology developments such as virtual meetings and video conferencing can reduce the need to be on a plane, they also open up new developments, such as virtual teams and home working and there is likely now a wealth of data on employee whereabouts available within your organisation.

While borders are becoming less important for the workforce, they remain a critical starting point for determining taxation and in particular the existence of a permanent establishment.  As explained in Episode 1, the reduction in the PE threshold triggered by the BEPS action plan will likely increase potential tax authority challenges in situations where employees cross borders to engage in activities such as contract negotiation.

In the third episode of our EMEA PE webcast series we will focus on the practical implications of having a globally mobile workforce and the type of PE challenges this can create.

PwC specialists from our international tax practice and our people & organisation practice will explain the typical PE issues that may arise from activities such as short term business visits and home working.  In addition they will consider approaches to monitoring data on employees and ways to identify and manage potential risk areas.

You will have the chance to raise questions directly to our PE specialists.

Speakers for episode three will include:

  • Monica Cohen-Dumani – Partner, International Tax Services, EMEA ITS Central Cluster Leader
  • Mike Cooper – Partner, International Tax Services, PwC UK
  • Sarah Mullen – Senior Manager, People & Organisation, PwC UK
  • Richard Brunt – Director, Value Chain Transformation, PwC Switzerland

Registration Link

Complete the required registration fields and select “Submit”.
Once you have registered, you will receive the WebEx access details. The WebEx will be recorded and you will receive a link to the recording via e-mail after the event using the same details. There will be time for questions and answers with your speakers during the WebEx. Questions can also be sent in advance of the
WebEx session to the following email address: grasiele.neves@ch.pwc.com

We do hope that you will join us online!

Best regards,

Monica Cohen-Dumani

Contact

Monica Cohen-Dumani
Partner, EMEA ITS Central Cluster Leader
+41 58 792 97 18
monica.cohen.dumani@ch.pwc.com

Grasiele Teixeira Neves
International tax services
+41 58 792 98 25
grasiele.neves@ch.pwc.com

 

 

EMEA ITS Permanent Establishment Webcast Series, Episode One

The Changing PE Threshold

Thursday, 8 June 2017, 3.00 – 3.45 pm CET

Preventing the artificial avoidance of Permanent Establishment (“PE”) status is one of the key topics addressed by the OECD’s Base Erosion and Profit Shifting (“BEPS”) package.

In this webcast series PwC specialists will address the practical implications that a reduction in the PE threshold will have for multinational corporations and will provide an insight, through examples, on the challenges and practical actions that can be taken to manage PE in the post-BEPS world.

The webcast series will provide a mix of technical updates and analysis, practical experience and local country expertise around topics such as profit attribution to a PE, direct tax consequences of a PE and the broader impact that the new rules will have on an increasingly global and mobile workforce. Critically, it will give you the chance to raise questions directly to our PE specialists.

The webcast series will start by setting the scene for the current PE landscape by considering the practical changes that have taken place to the PE threshold and the subsequently looking at the practical challenges associated with attributing profit to PE’s. The later sessions will focus on the practical implications of
these changes, providing guidance and experience of the challenges and risks that may be created.

  • Session 1 –The Changing PE Threshold – 8 June 2017
  • Session 2 –Profit Attribution to PE’s – 6 July 2017

After the summer break we will return recharged with further sessions covering topics such as

  • Broader implications of a PE beyond corporate tax
  • VAT and PE
  • Employee mobility and PE consequences

Episode 1, The Changing PE Threshold – 8 June 2017

This introductory episode will set the stage for our ongoing discussion of PE in the new tax environment and will work through practical examples being faced by multinational corporations, addressing questions such as:

  • What are the main developments in the definition of PE in the international environment?
  • Walk though practical examples to demonstrate how the changes related to: (1) fixed place of business, (2) auxiliary and preparatory exceptions, (3) independent and dependent agent, (4) antifragmentation and contract splitting are likely to work in practice and potential risk areas.
  • Assess how PE definition and interpretation may vary by local jurisdiction, taking Poland and Spain as examples to identify the impact this will have on a multinational’s approach to international business.
  • Provide an update on the multilateral instrument as it relates to PE.

Speakers for episode 1 are:

Monica Cohen-Dumani – EMEA ITS Leader
Guillaume Glon – PwC France
Mike Cooper – PwC UK
Agata Oktawiec – PwC Poland
Carlos Concha Carballido – PwC Spain
Please click on the below link to register for the WebEx session.

Registration Link

Complete the required registration fields and select “Submit”.
Once you have registered, you will receive the WebEx access details. The WebEx will be recorded and you will receive a link to the recording via e-mail after the event using the same details. There will be time for questions and answers with your speakers during the WebEx. Questions can also be sent in advance of the
WebEx session to the following email address: grasiele.neves@ch.pwc.com

We do hope that you will join us online!

Best regards
Monica Cohen-Dumani

PwC | Partner, International tax services, EMEA ITS Leader
Office: +41 58 792 9718 | Mobile: +41 79 652 14 77
Email: monica.cohen.dumani@ch.pwc.com
PricewaterhouseCoopers SA
Avenue Giuseppe-Motta 50 | Case postale | CH-1211 Genève 2, Switzerland
http://www.pwc.ch