Two key perspectives on permanent establishments

Vic 8th Annual Tax Forum Event

We caught up with Cameron Forbes from Clayton Utz, who will be presenting at the upcoming VIC 8th Annual Tax Forum Online, running online from October to November 2020, to talk about the corporate tax space and one of the ATO’s key focus areas: permanent establishments.

According to Cameron the challenges facing practitioners from a corporate tax perspective include, “identifying the key tax issues affecting corporate clients in this new and evolving COVID environment and providing strategic advice on how to respond to/navigate these.”

To tackle those major challenges, Cameron suggested that practitioners needed firstly to stay up to date with the key developments in the corporate tax sphere, but also to liaise with clients directly, in order to understand the issues impacting their business.

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And as someone who puts an emphasis on being up to date with the latest in his speciality, Cameron said he’s looking forward to the VIC 8th Annual Tax Forum Online for the, “many interesting topics that will be covered in respect of corporate tax including corporate tax residency and the capital / revenue distinction.”

“The in-house tax leaders facilitated discussion also promises to be a very insightful exploration of the current issues, challenges and opportunities facing corporate entities from a tax perspective,” he added.

This session on 5 November, Session 10: Tax policy and advocacy update, features The Tax Institute Senior Advocate, Robyn Jacobson, CTA, and Director of Tax Policy and Technical, Andrew Mills, CTA (Life).

Andrew and Robyn will discuss the need to turn our minds to genuine tax reform as we emerge from the COVID-19 crisis, covering the state of tax policy and the current activities of The Tax Institute’s policy and advocacy strategy.

Related: Explore the road to tax reform at The Tax Summit: Project Reform

Cameron’s presentation at the event, Session 9A: Permanent Establishments in 2020 and beyond, looks at Australian ‘permanent establishments’ (PE) - a key focus area for the ATO.

Driven by the increasingly online, globalised business world, we are seeing an increased presence of multinational companies in Australia. This expansion has lead to the existence of permanent establishments, which the session will examine from a unique standpoint.

“I will be co-presenting with Amber Agustin who leads the Melbourne Tax Practice at Clayton Utz and specialises in revenue litigation and disputes,” Cameron explained.

“As I specialise in corporate tax advisory in the transactional context, we will be providing a unique perspective by examining recent trends and developments in the ever evolving area of "Permanent Establishments" from both a disputes and transactional perspective - which is particularly relevant in the corporate sphere given it is currently a key focus area of the Australian Taxation Office.”

From a disputes context, Cameron and Amber will cover strategies for engaging with the ATO on PE disputes and what taxpayers can do to support their PE position. On the transactional side of things, delegates will hear about Australian PE issues including the impact of an increased presence of non-resident personnel in Australia, electronic commerce and the temporary displacement of non-resident personnel due to COVID-19.

Attend the VIC 8th Annual Tax Forum Online – no matter where you are

Running over four weeks from September 15 to 5 October 2020, the VIC 8th Annual Tax Forum Online promises a program designed to equip you with the latest knowledge and information so you can continue to best advise and assist your clients through COVID-19 and beyond.

Open to tax professionals around the country, this virtual event is a must-attend for practitioners looking to sharpen their tax knowledge.


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According to Cameron, CPD events like the VIC 8th Annual Tax Forum Online are “a great opportunity to hear from the regulators, fellow tax professionals and corporate in-house teams about topical corporate tax issues.”

“[Tax professionals] will have the opportunity to learn from the experiences of their industry peers in relevant areas of tax, and draw on these insights when advising their own clients.”

About Cameron Forbes

Cameron Forbes


As a corporate tax lawyer with Clayton Utz, Cameron Forbes advises on income tax, stamp duty, and GST in the context of large corporate transactions, including providing tax advice and drafting tax clauses for some of the largest and most complex Australian corporate transactions in recent years.

Before joining Clayton Utz, Cameron worked with King & Wood Mallesons, and in the legal division of the State Revenue Office Victoria.


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