Permanent establishment taxation compact
Practical knowledge and recommendations for action
4.5
Contents
Definition of permanent establishment and types of permanent establishment
- Overview of current legislation, case law and announcements.
- National and international regulations.
- Overview of the individual types of permanent establishment (fixed place of business, construction/assembly permanent establishment, agency permanent establishment, service permanent establishment) and delimitation.
- Presentation of special cases (e.g. server location, home office, subcontracting).
The AOA and its application
- The Authorized OECD Approach (AOA) in theory and its implementation in Germany.
- Exceptions to the application of the AOA.
- Step-by-step determination of the operating result.
- Dealings and transfer pricing methods.
- Implementation via imputation and exemption method.
Administrative effort and documentation
- Registration and deregistration of business premises.
- Documentation in accordance with § 90 (3) of the German Fiscal Code.
- Auxiliary and secondary calculation.
Outlook
- Further developments at OECD level and implementation of the multilateral instrument.
- Effects of implementation in national law.
Learning environment
In your online learning environment, you will find useful information, downloads and extra services for this training course once you have registered.
Your benefit
Get in this training event a. o.
- an overview of the current regulations on the taxation of international permanent establishments,
- Explanations on the concept of a permanent establishment and the different types of permanent establishments,
- a guide to the procedure for determining the permanent establishment result,
- Recommendations for action regarding the necessary administrative activities and documentation in connection with business premises and
- an up-to-date outlook on upcoming tax law changes in this area.
Methods
Lecture, practical examples and sample cases, design examples and discussion of individual cases. The speaker will be available for individual questions and problems.
Recommended for
Specialists and managers from finance and accounting, controlling, tax departments and commercial management.
- Customized training courses
- Direct application in practice
- Efficient use of time and resources
Ratings and feedback from our participants
Start dates and details
Thursday, 25.06.2026
09:00 am - 5:00 pm
Thursday, 24.09.2026
09:00 am - 5:00 pm
Tuesday, 27.10.2026
09:00 am - 5:00 pm
Friday, 19.02.2027
09:00 am - 5:00 pm
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