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Where do I lay my hat?
Key points
- Typical fact patterns that Covid-19 measures have driven.
- Implications of containment measures for corporate tax residence.
- Tax authorities’ guidance on a company’s central control and management.
- Existence of permanent establishments and allocation of profits.
- Individuals may become inadvertently resident in another country.
- Payroll matters should also be monitored.
The current Covid-19 crisis is bringing to the fore various novel international tax issues that have not previously needed to be considered either by taxpayers or tax authorities. Rightly the focus of governments and businesses has been on health safety and from a pure tax perspective fiscal stimulus and cash flow measures. However as businesses and tax authorities come through the initial reactive stage consideration...
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