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Article summary

The Organisation for Economic Cooperation and Development (OECD) has updated its guidance on tax treaties following the impact of the coronavirus (COVID-19) pandemic. The OECD has highlighted that due to the ongoing public health emergency, ‘unprecedented measures’ were imposed by governments including ‘travel restrictions and curtailment of business operations’. The guidance aims to provide the OECD Secretariat’s views on the interpretation of the provisions of tax treaties in the context of the coronavirus pandemic, but recognises that tax administrations in each jurisdiction may adopt their own guidance to give taxpayers certainty. It addresses concerns related to the creation of permanent establishments, change of residence, and income from employment.