Tax Treaty Case Law around the Globe

Permanent Establishment

Session 2: Tax treat case law around the globe 2022

In each session of the hybrid conference, tax treaty cases will be presented and subsequently analyzed in a critical discussion. This discussion includes the possible impact of the cases on the interpretation and application of tax treaties in other countries. Participants are invited to join the discussions actively. The scientific results of the conference will be published in a book by the IBFD. 

Date and time

  • Friday, May 13, 2022, 11:05-12.25 
    All time slots are Central European Time (CET). 


  • Tilburg University, Dante Building, Room DZ 2, Warandelaan 2, 5037 AB, Tilburg or
  • Online




Speaker Location
D.P. Sengupta Online

Is there involvement of the PE in a turn-key project for Setting up a plant?

  • Technip France SAS - Authority for Advance Ruling, 2 February 2021
  • Case No: AAR No.1413 of 2012


Speaker Location
Marjaana Helminen Online

Is there a PE under article 5(1) of DTT? If so, whether the activities were of a preparatory or auxiliary character under Art. 5(5) of the DTT

  • Korkein Hallinto-oikeus (Supreme Administrative Court), 3 December 2021
  • Case No: KHO 2021/H4294 (171)


Speaker Location

Gugliemo Maisto

Cesare Silvani

On Campus

On Campus

Retrospective appliation of the OECD Reports on the attributio of profits to PEs

  • Supreme Court, Tax Chamber (Cass. Civ. Sez. Trib.)  25 March 2021
  • Case No: 8500


Speaker Location
Cihat Öner On Campus

Understanding of the concept of PE under Turkey-Germany DTT Attribution of income to a PE

  • Supreme Administrative Court, 4th Chamber, 18 January 2021
  • Case No: 2016/16413 E.,  2021/297 K.