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International taxation issues at the time of Coronavirus (Nr. 906)

Following the current situation, with many countries taking measures to restrict the movement of persons and introducing strict quarantine measures, the OECD has issued an analysis on the impact of these measures on international taxation. A complete opinion in English is available here. Below, please find short summary.

The OECD analysis comments on areas such as the creation of permanent establishments because of  home office, the actual place of company management, the impact on individuals' tax residence or the state of taxation of wage compensation for people living in one state and working in another.


The analysis particularly highlights that the current situation is a temporary situation and apparently caused by objective circumstances without the possibility of being influenced by the taxpayers. In this context, it mentions that any conclusion resulting from the application of international double tax treaties should be made based on situation like the usual situation (without the influence of an existing coronavirus pandemic).

Special attention should be paid to the time test FOR CONSTRUCTION SITES OR FOR CONSTRUCTION-ASSEMBLY WORKS, where even in the event of interruption of work due to a coronavirus pandemic, this period counts down to a TIME TEST affecting the establishment of a permanent establishment.

KODAP Advisers are ready to help you assess the impact of the current situation on international taxation.
Further pandemic-related tax, legal and economic information can be found on the Pandemic Information section of our website.

publikováno 24.04.2020
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