This guidance is intended to provide more certainty to taxpayers during this exceptional period of Covid pandemic.
The guidance is relevant only to circumstances arising during the COVID-19 pandemic when public health measures are in effect. It seeks to avoid instances of double taxation but not to create instances of double non-taxation. Much of the analysis covers circumstances where factual determinations by tax administrations are required and the guidance does not purport to replace the judgement of tax administrations in those cases.
The guidance recognizes that some businesses may be concerned that employees could create a permanent establishment if they are working from home in a country other than that in which they regularly work. The creation of a permanent establishment could create new tax and filing obligations for the business.