Navigating permanent establishment risk in a remote work era - Part I

This article examines the interpretative framework for assessing PE risk in a remote work context and the relevance of the OECD MTC Commentary under domestic law and tax treaties.

Remote working increased significantly during the COVID-19 pandemic and has since become a long-term feature of today's working environment. Global workforce mobility remains a key issue for multinational groups, driven by the need to retain talent and adapt to employees' growing expectations for flexibility. This evolution has not only reshaped expectations around where and how work can be performed but has also required organisations to rethink workforce strategy, internal governance, and...

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Authors: Conrad Turley, Raluca Enache

Published Date: 10 June 2026