Beyond Borders: Practical Frameworks to Navigate Permanent Establishments and Profit Allocations in a Home Office Setting

Working abroad from home is a growing trend in today’s working landscape, which has not yet been reflected in the OECD Model. Therefore, this article proposes amendments to article 5 of the OECD Model to capture the establishment of home office PEs and also covers the profit allocation thereto. The recommendations made aim to find a balance between fair taxation, proportionality and simplification.