Implications of Covid-19 measures on tax residence and permanent establishment

The current Covid-19 crisis is bringing to the fore various novel international tax issues that have not previously needed to be considered either by taxpayers or tax authorities. Rightly the focus of governments and businesses has been on health safety and from a pure tax perspective fiscal stimulus and cash flow measures. However as businesses and tax authorities come through the initial reactive stage consideration will need to be given to some of the wider implications of the global containment measures.

A key issue will be the impact of such measures on:

• corporate tax residence;
• the existence of taxable permanent establishments; and
• individual tax residence.

These issues are dependent on where individuals are physically located and what they do in those locations. Further ...