Programme Synopsis
Decisions of influential courts from around the world are shaping the interpretation and application of double taxation agreements (DTA). How are some key treaty concepts such as permanent establishments (PE), beneficial ownership, royalties and service fees interpretated internationally? What can be learned from these international cases for tax planning around the region? Among the highlights:
- Is shared office space a PE? Can one office be a PE for two enterprises?
- In which cases is a subsidiary also deemed a PE?
- How much substance is enough to deem a holding the beneficial owner?
- Is use of a data centre a royalty under DTAs?
- PE’s for e-commerce
- When is a holding deemed a “conduit company”?
- Which software fees are royalties for the DTA?
- Are upfront fees paid to a lender interest under the DTA?
- What is the difference internationally between services and royalties?
- Capital gains on sale of shares and DTA exemptions
- In which situations can Vietnam, Thailand, Bangladesh and Laos tax gain on shares realized by a Singapore shareholders?
Join Accredited Tax Advisor (Income Tax), Mr Edwin Vanderbruggen, an international tax expert formerly lecturing at universities in Europe and Asia, in a highly practical and to-the-point analysis of some interesting landmark court cases from around the world.
Fees will be $41.42 for SCTP members and VDB Loi clients and contacts.
This webinar is pending SILE-accreditation.
Participants who wish to obtain CPD Points are reminded that they must comply strictly with the Attendance Policy set out in the CPD Guidelines. For this activity, this includes logging in at the start of the webinar and logging out at the conclusion of the webinar in the manner required by the organiser, and not being away from the entire activity for more than 15 minutes. Participants who do not comply with the Attendance Policy will not be able to obtain CPD Points for attending the activity. Please refer to www.sileCPDcentre.sg for more information.
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Speaker
Edwin Vanderbruggen
Senior Partner
VDB Loi
Edwin Vanderbruggen is the senior partner of VDB Loi, a leading legal, tax and non-regulated services advisory firm with offices in Bangladesh, Cambodia, Myanmar, Laos, Vietnam and Indonesia. Edwin has advised Governments, international financial institutions, oil and gas supermajors, independent power producers, commercial banks, mobile network operators and other multinationals on some of the region’s largest projects and deals.
Edwin has 30 years’ experience as a legal and tax adviser, author, government adviser and academic. He has regularly advised Governments, the World Bank and the Asian Development Bank in Southeast Asia, drafted laws and regulations and has supplied expert testimony to courts.
Edwin previously lectured international tax law in six universities across Europe and Asia. He has also published more than forty scientific articles in international legal journals and six textbooks on international law, taxation and investment law issues, some of which won scientific awards.
