June 16, 2023 Thursday, June 29 | BorderCrossings . . .With EY transfer pricing and tax professionals (1 pm ET) Profit attribution to permanent establishments: how do transfer pricing principles apply? While transfer pricing under the arm’s-length principle is most often applied to transactions between separate legal entities, it can also apply to attribute profits to permanent establishments. Under US tax treaties, Article 7 governs profit attribution to permanent establishments, and references the arm’s-length principle under Article 9. Under the Internal Revenue Code, the tax treatment of branches falls under the “effectively connected income” (ECI) rules. This webcast will discuss the following questions:
You might be surprised by the answers. We hope you will be able to join us for this important webcast. Date: Thursday, June 29, 2023 Time: 1:00–2:15 p.m. ET New York/Toronto; 10:00–11:15 a.m. PT Los Angeles/Vancouver Registration: View archive here. Panelists
CPE credit offered: 1.4. Recommended field of study: Taxes. Learning objectives: Analyze the interaction of US domestic law rules and treaty rules as they apply to permanent establishments. Describe the history of Article 7 interpretation, including the OECD Authorized Approach to profit attribution. Final CPE award to be based on content, polling and length of participation. See CPE FAQ for more information. EY webcast managed and produced by Ernst & Young LLP’s Tax Technical Knowledge Services Group, Washington, DC: Lynn Fairfax | lynn.fairfax@ey.com and Andrea Ben-Yosef | andrea.ben-yosef@ey.com Learn about and register for EY Tax Webcasts Register for EY’s Tax News Update so you don’t miss any EY Tax Webcasts: taxnews.ey.com/register | ||||
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