COVID-19 had the entire world in flux in the early years of this decade. The health crisis was instrumental in shaping perceptions of a regular 9-5. The world had to come to terms with the fact that travelling to the office every day was no longer feasible. It also had to make peace with the reality that even in the absence of a physical office, work could still be done.

Over time, the virus has largely been dealt with. Its impact on how people work, however, has become the norm. Many employees now work remotely. In this backdrop, the Organisation for Economic Co-operation and Development (OECD) released revisions to its Commentary on the Model Tax Convention regarding the interplay of permanent establishments and remote work. These revisions aim to provide clearer guidance on the circumstances under which remote working arrangements may constitute a permanent establishment for an enterprise in a foreign jurisdiction. This would enable the so-called source country or the country where the permanent establishment is present to assert its taxing rights and expand its revenue base.