OECD Secretariat analysis of tax treaties and the impact of the COVID-19 crisis

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The Organisation for Economic Co-operation and Development ("OECD") Secretariat has published an analysis on various international tax issues that companies may encounter during the current COVID-19 crisis.

The OECD Secretariat's comments relate to (i) the creation of permanent establishments, (ii) the residence status of a company (place of effective management), (iii) cross-border workers and (iv) a change to the residence status of individuals.

On these various subjects, the OECD Secretariat considers that the practical but temporary implications of the COVID-19 crisis (e.g., teleworking from home, containment of individuals away from their usual place of residence, inability for cross-border workers to access their place of work, temporarily transfer of the place of effective management of a company due to the containment conditions of its chief executive officer and other senior executives) should not involve tax consequences.

This analysis can be downloaded by clicking on this link.


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