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Info Seminar DDTC 17/3/15 : Fundamental Concept of Permanent Establihment

DANNY DARUSSALAM Tax Center (DDTC) – 2015 Training Programs No Images? Click here




09.00AM – 05.00PM


The question arises from non-resident companies in carrying on business activities in the source country, whether to carry on business through a Permanent Establishment (PE)? The answer to this question might be “yes” and “no”. If so, for those who want to carry on their business activities through a fixed place of business, dependent or independent agents, and hope can certainly carry on their business activities in the source country. Unless, if non-resident intended to avoid administrative tax burden in source country or in other words, not subject to domestic taxation therein.

However, to determine the existence of a PE, it needs to consider the relevant factors associated with the time threshold or the activity undertaken in the source country. Not to mention the existence of the declaration of the G20 with the OECD, which include the issue of PE in 15 Plan of Action on the issue of the Base Erosion and Profit Shifting (BEPS Action Plan). BEPS Action Plan 1, the OECD and the G20 will focus on addressing issues in PE that was developing in the information technology industry and digital communications. Then BEPS Action Plan 7, the OECD and the G20 will lower the threshold of PE to provide more taxing rights to the source country.

In this valuable seminar, you will capture clearly concept of PE in performing cross border transactions between the companies in treaty partner.

With material that we have to offer the following:


Presented by:


Ganda C. Tobing

Senior Manager of International Tax/Research & Training Services, DDTC

He was in charge in reviewing, designing, and controlling of tax compliance and litigation of Multinationals Companies. He has vast proven track records in settling tax litigation cases for companies… More details


Yusuf W. Ngantung

Senior Manager of International Tax/Transfer Pricing Services, DDTC

He is an experienced practitioner involved in international tax, dispute resolution, and transfer pricing projects. He is a regular speaker in topics regarding international taxation and… More details


Who should attend:

The seminar is valuable for Corporate tax Adviser; International tax expert and executives; Tax professional and controller; Tax attorneys; Accountants; and Anyone else who have responsibilities on taxation.


Key Benefits of Attending:

  • With the existence of fundamental analysis of the concept of permanent establishment, participants can gain permanent allocation establishment which has been the debate of academics, practitioners, tax authorities and international organizations;
  • Through Functional Analysis of permanent establishment, participants have the power to deal with the findings of the tax authorities;
  • Guiding participants to not get stuck in the double taxation;
  • With the existence of explanation of the current issue of the permanent establishment, participants can identify the elements of permanent establishment so they can decide whether a business including permanent establishment or not.


IDR 3.000.000 per person 
This seminar is limited to only 24 participants to ensure an effective learning environment and to promote interactive discussions.
For further enquiries, please contact:
Ms Eny Marliana at +62 815 898 0228 or email to
Ms Indah Kurnia at +62 856 192 6643 or email to



DDTC’s Training Center
Menara Satu Sentra Kelapa Gading
6th Floor – Unit #0601 – #0602
Jl. Boulevard Kelapa Gading LA3 No.1
Jakarta Utara 14240


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Menara Satu Sentra Kelapa Gading
 5th & 6th Floor – Unit #0501 & Unit #0601-0602
Jl. Boulevard Kelapa Gading LA3 No.1
Summarecon, Kelapa Gading
Jakarta Utara 14240
Indonesian Tax Firm, Worldwide Knowledge

Maret 7, 2015 Posted by | Adv. Seminar | , | Meninggalkan komentar



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