Seminar dan Pelatihan Pajak

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Fundamental Concept of Permanent Establishment


Tuesday, 17th March 2015 | 09.00 AM – 05.00 PM

Menara Satu Sentra Kelapa Gading 6th Floor,
Unit #0601 – #0602
Jl. Boulevard Kelapa Gading LA3 No.1 Summarecon
Kelapa Gading Jakarta Utara 14240


Ganda Christian Tobing
GANDA CHRISTIAN TOBING is the Senior Manager of International Tax Services

Yusuf Wangko Ngantung
YUSUF WANGKO NGANTUNG is the Senior Manager of International Tax / Transfer Pricing

IDR 3.000.000 per person.
This seminar is limited to only 24 participants to ensure an effective learning environment and to promote interactive discussions



The question arises from non-resident companies in carrying on business activities in the source country, whether to carry on business through a Permanent Establishment (PE)? The answer to this question might be “yes” and “no”. If so, for those who want to carry on their business activities through a fixed place of business, dependent or independent agents, and hope can certainly carry on their business activities in the source country. Unless, if non-resident intended to avoid administrative tax burden in source country or in other words, not subject to domestic taxation therein.

However, to determine the existence of a PE, it needs to consider the relevant factors associated with the time threshold or the activity undertaken in the source country. Not to mention the existence of the declaration of the G20 with the OECD, which include the issue of PE in 15 Plan of Action on the issue of the Base Erosion and Profit Shifting (BEPS Action Plan). BEPS Action Plan 1, the OECD and the G20 will focus on addressing issues in PE that was developing in the information technology industry and digital communications. Then BEPS Action Plan 7, the OECD and the G20 will lower the threshold of PE to provide more taxing rights to the source country.

In this valuable seminar, you will capture clearly concept of PE in performing cross border transactions between the companies in treaty partner.

Who should attend:

The seminar is valuable for Corporate tax Adviser; International tax expert and executives; Tax professional and controller; Tax attorneys; Accountants; and Anyone else who have responsibilities on taxation.

Key Benefits of Attending:

  1. With the existence of fundamental analysis of the concept of permanent establishment, participants can gain permanent allocation establishment which has been the debate of academics, practitioners, tax authorities and international organizations;
  2. Through Functional Analysis of permanent establishment, participants have the power to deal with the findings of the tax authorities;
  3. Guiding participants to not get stuck in the double taxation;
  4. With the existence of explanation of the current issue of the permanent establishment, participants can identify the elements of permanent establishment so they can decide whether a business including permanent establishment or not.


For further inquires please contact:
Ms Eny Marliana
Mobile : +62 815 898 0228
Email :

Ms Indah Kurnia
Mobile : +62 856 192 6643
Email :

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