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"Lockdown", Covid-19 and Double Taxation Treaties

Publication at Faculty of Law |
2020

Abstract

The Article focuses, from the point of view of double taxation treaties, on selected issues, the tax consequences of which have been widely discussed among experts in connection with measures taken in response to the Covid-19 pandemic. The significant restrictions on the free movement of persons and the consequent impossibility of carrying out activities in places where they would have been carried out under "normal" circumstances may be named as the triggers for these debates.

The article focuses on the issues of tax residency, permanent establishments and income from employment.