F. Alfredo García PratsBorn in Castellón, in 1966. Doctor in Law with Extraordinary Honors (1994) with his thesis on permanent establishments in international tax law. Professor of Financial and Tax Law at the University of Valencia (Spain) since 1997; Jean Monnet Chair on ‘EU Law and taxation’; visiting professor at the Universities of London, Harvard, Leiden, Leuven, Bergamo, Bocconi, Salamanca, and Toledo, Professor García Prats specializes in international tax law, EU tax law, and tax principles. Observer and Adviser of the Ad Hoc Group of Experts on International Cooperation in Tax Matters of the United Nations since 1995 and of the Fiscal Committee of the United Nations from 2005 till 2008, Senior Counsel at the IMF in 2008, member of the scientific committee of various tax and international tax journals.
This course analyzes the concept and the different types of permanent establishment, the importance of permanent establishments in trans-national businesses, and the functions of PE clauses in domestic tax law and double tax treaties. Special attention will be given to construction projects, auxiliary activities, agents and sales representatives, and to supply chain structures. The attribution of profits to permanent establishments will also be dealt with, with special reference to and analysis of the OECD Guidelines in this regard. Attention will be paid to the influence of EU law for the taxation of permanent establishments in international tax law.
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