SECOND EUROPEAN REGION CONFERENCE

MILAN 20-21 MAY 2021 – HOTEL PRINCIPE DI SAVOIA

Five sessions in two days!  Here some details on session one:

MOBILITY OF WORK (CORPORATE TAX ASPECTS)

Chair: Jonathan Schwarz

  • Physical Presence in the Source State and PE threshold
  • Supervisory activities and PE
  • Secondment of employees
  • Attribution of PE income
  • UN Model and technical services
  • Corporate residence and executive mobility

 

The first part of the Plenary I shall cover the corporate tax ramifications of the mobility of workers focusing on activities conducted within MNEs relating to both business and staff functions (e.g. supervision of foreign subsidiaries), both through the use of contractors and employees. The panel will cover (a) PE threshold (i.e., magnitude and character of physical presence required to establish a PE); (b) if and under when supervisory activities conducted by the parent company’s personnel in the country of residence of the subsidiary may constitute a PE; (c) when secondment of employees creates a PE; (d) cost, transfer pricing and VAT issues relating to employee secondment; (e) determining PE profit from worker activity; (f) interaction between PE and technical service fee treatment; (g) executive mobility and corporate residence also having regard to vertical models of governance and reporting lines by function rather than entity.