OECD: Updated guidance on tax treaties (COVID-19)

OECD: Updated guidance on tax treaties (COVID-19)

The Organisation for Economic Cooperation and Development (OECD) today released updated guidance on tax treaties and the effect of the coronavirus (COVID-19) pandemic.


Measures imposed or recommended by governments, including travel restrictions and curtailment of business operations, have been in effect in most jurisdictions in various forms and stages during most of 2020 due to the COVID-19 pandemic, and this situation continues in 2021.

According to an OECD release, the “note” revisits guidance issued in April 2020. Read TaxNewsFlash

The updated guidance:

  • Represents the OECD's views on the interpretation of the provisions of tax treaties intending to provide greater certainty
  • Illustrates how some jurisdictions have addressed the effect of COVID-19 on the tax situations of individuals and employers
  • Outlines the application of the existing rules and the OECD commentary on concerns related to the creation of permanent establishments, the application of "tie-breaker" rules to dual residents, and the tax treaty treatment of income from employment

Read a February 2021 report prepared by the KPMG member firm in the UK

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