Permanent Establishments: Tax Dangers from Cross-Border Activities

Richard Stuart Collier, Partner, Banking and Capital Markets, PricewaterhouseCoopers (London)

Taxation Committee

As the world economy grows, cross-border activities are on the rise. Business people travel regularly and extensively to other countries. Employees in one country sign contracts on behalf of colleagues in other countries, activities that create serious tax exposures (or permanent establishments) for the entity who earns the income. Across the world, taxpayers and tax professionals are increasingly focused on these issues.

PricewaterhouseCoopers London partner Richard Collier will discuss these problems and responses from tax authorities. He will also focus on how the issue can be managed, highlighting new developments in this area, including the actions of the tax authorities focusing primarily on Europe and Asia. Richard will raise and consider relevant technical positions under double tax treaties following OECD principles. Finally, Richard will discuss the likely scale of the problem and identify particular areas of difficulty, including how to approach the tax risk management of these issues in practice.

Richard, global leader of PwC's London Banking and Capital Markets tax team, has specialized in banking and capital markets tax issues for 20 years. He has been closely involved in some major tax changes to the sector in London over recent years, including the new approach to transfer pricing in the financial sector and the OECD tax approach to profit allocation for permanent establishments.

Richard completed research in taxation at the universities of Cambridge (LL.M. thesis on transfer pricing) and London (Ph.D. thesis on developments of tax treaties and implications of CFD rules) and is a chartered accountant and barrister. He is a member of Council of the Institute for Fiscal Studies and writes and lectures extensively on taxation.