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Private client review for February 2021

This month’s private client update, by Edward Reed and Tristan Honeyborne (Macfarlanes).

Covid-19 travel restrictions and UK residence issues for overseas workday relief

Practitioners concerned about the multifaceted impact of the covid-19 lockdown restrictions on residence taxation and compliance greeted with some relief the publication on 3 April 2020 of the measured OECD Secretariat guidance on the interpretation of double tax treaties in the context of lockdown restrictions. As those restrictions remain in place nearly a year later and as the individual guidance of different revenue authorities locally has proved less than sympathetic to various unusual cross-border fact patterns that have emerged the publication of a refreshed piece of guidance by the OECD Secretariat on 21 January 2021 is to be welcomed.

The tone of the 2020 guidance is perhaps best summed up by paragraph 36 which reads ‘because the covid-19 crisis is a period...

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