The impact of the COVID-19 measures on the allocation of taxing rights between States as laid down in the OECD Model Convention
On 3 April 2020, the OECD Secretariat published guidelines on the impact of the COVID-19 measures on the allocation of taxing rights between States as laid down in the OECD Model Convention (“OECD Secretariat Analysis of Tax Treaties and the Impact of the COVID 19 Crisis”).
The guidelines do not discuss specific treaty provisions that would deviate from the OECD Model Convention.
The guidelines concern a) the residence of a company (place of effective management); b) the residence of an individual; c) the presence of a permanent establishment and d) international employment.
Linda Brosens and Stephanie van Gils take a closer look at these four aspects in the magazine Internationale Fiscale Actualiteit.
You can read it here.
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