COVID 19 - Impact on Tax Treaties interpretation and TP

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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