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Permanent Establishment Issues Under COVID-19 Analyzed by Deloitte
The tax division of global consultancy Deloitte in May 2020 published an analysis of permanent establishment and corporate residency issues in the context of the COVID-19 crisis. In a nutshell, employees stranded in a foreign country and performing remote work from there could unwittingly create a “permanent establishment” and/or a de-facto “corporate presence” in that country, which in turn would trigger tax consequences, potentially making their employer liable for