About this Event
Cross-border home working challenges the conventional concept of permanent establishment, which developed around identifiable commercial premises. Digital technology now permits individuals to perform sustained and economically significant functions for an enterprise in a jurisdiction where the enterprise has no formally established office or branch. The OECD’s 2025 Update to the OECD Model Tax Convention introduces a revised approach to this issue. Working from a home for less than 50 per cent of total working time will generally not create a place of business. Reaching that threshold does not itself establish a permanent establishment; the wider circumstances, including whether the individual’s presence commercially facilitates the enterprise’s business in the host State, remain important. Using Australia as a case study, the discussion considers how this approach interacts with domestic law, tax treaties, withholding taxes and profit-attribution rules. It evaluates when sustained home working should establish a sufficient business presence in the host State and how jurisdictions might implement the OECD’s approach without treating personal relocation, employee retention or reduced office costs as sufficient in themselves.
Event venue & nearby stays
Tax Academy of Singapore Hub, 55 Newton Road, Toa Payoh, Singapore
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