The COVID-19 pandemic has raised several concerns among the tax
practitioners, the MNE and the Tax Authorities around the world:
- residence status of individuals;
- cross border workers;
- residence status of a company (place of effective management);
- creation of permanent establishments;
- effects on the application of the OECD PPT and some national;
- GAARs and/or SAARs;
- effects on Transfer Pricing.
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