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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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...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes: