Introduction

The unprecedented change in the economic environment following the outbreak of COVID-19 has given rise to new restrictions imposed by governments around the world, resulting in a significant disruption to the locations where businesses operate and people work. As businesses have to change the way in which they operate to cope with the new situation, tax issues inevitably arise in various areas, including (i) tax residence of companies; (ii) tax residence of individuals; (iii) permanent establishment; (iv) employment income of cross-border employees; and (v) transfer pricing.…