Few provisions carry as much weight in international taxation as Article 5 and Article 7. Article 5 decides whether a country may tax a foreign enterprise; Article 7 decides how much profit is attributed to it. This Master Series takes you through the complete arc — from establishing tax nexus to attributing profit — woven throughout with the OECD Commentary, the UN Model Convention, leading judicial precedents, and practical case studies.
On Permanent Establishment — concepts, controversies and court decisions.
Comprehensive, up-to-date commentaries on Article 5 and Article 7, authored by Dr. Mehta.
60+ on PE and 90+ on Article 7 issues, for deeper self-study.
High-quality, real-world case studies discussed across the live sessions.
Full session recordings and presentation slides for every session.
Certificate of Participation on completion of the programme.
All programme resources remain accessible until March 2027.
Enrol in either programme individually, or take both together at a combined saving of more than 33%.
Early Bird pricing is available for a limited period. Cohort size is limited to preserve the interactive quality of every session — early enrolment is recommended.
For team/ group seats and enrolment outside India, please contact us via email at support@dramarmehta.online
Dr. Amar Mehta brings more than 33 years of experience in international taxation, advising clients across multiple jurisdictions and industries on the most demanding questions in cross-border taxation — from inbound and outbound structuring to treaty interpretation, characterisation disputes, and complex controversy matters. He is the author of a comprehensive commentary on Permanent Establishment and a regular speaker at international tax conferences.
Join a serious cohort of Chartered Accountants, tax lawyers, transfer-pricing specialists and corporate tax teams — and study PE and profit attribution the way they are argued in practice.