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The OECD has opened a sweeping review of how global tax rules are failing to keep pace with the explosion of cross-border remote work, warning that long-standing concepts — from individual tax residence to permanent establishment (PE) thresholds — are being stretched to breaking point. The consultation, open until 22 December, seeks concrete evidence of how mobile workforces are triggering double taxation, dual residency, profit-attribution disputes and compliance burdens for companies that never intended to have any presence in the jurisdictions now asserting taxing rights.
The OECD says tax systems built around “where work is exercised” are increasingly misaligned with a world in which employees deliver services digitally from locations unrelated to their employer, their reporting chain or even their economic centre of life. Analysts say this has created a class of “virtual frontier workers,” often thousands of kilometres away from the jurisdictions that claim the right to tax them.
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