Mobility of Work

Mobility of Work
The book comprises 33 national reports from countries across the globe and is the outcome of a conference on mobility of work that took place from 7-10 July 2022 in Rust (Austria). More than 100 experts, including the authors of the national reports, were brought together to discuss recent developments in the field of mobility of work with special regard to the developments during the COVID-19 pandemic. The general report highlights the most important findings of the conference.

Why this book?

Cross-border activities of enterprises and individuals alike relate to the essence of international taxation. Thus, it is hardly surprising that mobility of work has long been a subject of discussion in international tax law. The outbreak of the COVID-19 pandemic constituted an accelerator of this phenomenon, with many more employers, employees and tax authorities suddenly forced to deal with the tax consequences of cross-border remote work. The aim of this book is to provide tax authorities, policymakers, courts and practitioners with an overview of the characteristics of employment income (article 15 of the OECD Model) in the context of work mobility, with particular consideration to the frontier worker provisions in some bilateral tax treaties and the establishment of permanent establishments in connection with mobility-related constellations such as home offices. This book also contains a systematic legal comparison on the taxation of work-related income under domestic law and a compilation of pandemic-related consultations of national tax authorities and governments. In the final section of each report, the authors strive to give an outlook on the future of mobility of work in international tax law.

This book is part of the WU Institute for Austrian and International Tax Law - Tax Law and Policy Series

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Editor(s)

Georg Kofler, Michael Lang, Pasquale Pistone, Alexander Rust, Josef Schuch, Karoline Spies, Claus Staringer, Rita Szudoczky

Assistant Editors: Stefano Castagna, Vera Hellebrandt

Author(s)

Kerrie Sadiq, Richard Krever, Jürgen Romstorfer, Stefanie Stöcklinger, Jean-Philippe Van West, Stefaan De Baets, Pieter Deré, Bart Van den Bussche, Luís Eduardo Schoueri,  Renan Baleeiro Costa, Felipe Yañez, Sergio Ayala, Na Li, Cristian Camilo Rodriguez Peña, Nevia Čičin-Šain, Željko Martinović, Dalibor Legac, Eleni Apostolidou, Jiří Kostohryz, Jana Tepperová, Mika Nissinen, Michael Mautsch, Gilles Querbach, Christina Dimitropoulou, Abhishek Padwalkar, Siddhesh Rao, Shipra Padhi, Atika Ritmelina Marhani, Riyhan Juli Asyir, Yurike Yuki, Tamir Shanan, Mario Tenore, Ruth Wamuyu, Joy Waruguru Ndubai, Patrick Knörzer, Andrian Candu, Raymond Adema, Irene J.J. Burgers, Aleksandra Maksimovska Stojkova, Elena Neshovska Kjoseva, Eivind Furuseth, Marisa Ouro, Matej Kačaljak, Mateja Babič, Jennifer Roeleveld, José Manuel Almudí Cid, Félix Alberto Vega Borrego, Katia Cejie, Peter Hongler, Tabea Lorenz, Dilpreet K. Dhanoa, Svitlana Buriak, Doron Narotzki

Mobility of Work
General Report
Chapter 1: The Impact of Tax Treaties on International Mobility of Work in Australia
Chapter 2: The Impact of Tax Treaties on International Mobility of Work in Austria
Chapter 3: The Impact of Tax Treaties on International Mobility of Work in Belgium
Chapter 4: The Impact of Tax Treaties on International Mobility of Work in Brazil
Chapter 5: The Impact of Tax Treaties on International Mobility of Work in Chile
Chapter 6: The Impact of Tax Treaties on International Mobility of Work in China (People’s Rep.)
Chapter 7: The Impact of Tax Treaties on International Mobility of Work in Colombia
Chapter 8: The Impact of Tax Treaties on International Mobility of Work in Croatia
Chapter 9: The Impact of Tax Treaties on International Mobility of Work in Cyprus
Chapter 10: The Impact of Tax Treaties on International Mobility of Work in the Czech Republic
Chapter 11: The Impact of Tax Treaties on International Mobility of Work in Finland
Chapter 12: The Impact of Tax Treaties on International Mobility of Work in Germany
Chapter 13: The Impact of Tax Treaties on International Mobility of Work in Greece
Chapter 14: The Impact of Tax Treaties on International Mobility of Work in India
Chapter 15: The Impact of Tax Treaties on International Mobility of Work in Indonesia
Chapter 16: The Impact of Tax Treaties on International Mobility of Work in Israel
Chapter 17: The Impact of Tax Treaties on International Mobility of Work in Italy
Chapter 18: The Impact of Tax Treaties on International Mobility of Work in Kenya
Chapter 19: The Impact of Tax Treaties on International Mobility of Work in Liechtenstein
Chapter 20: The Impact of Tax Treaties on International Mobility of Work in Moldova
Chapter 21: The Impact of Tax Treaties on International Mobility of Work in the Netherlands
Chapter 22: The Impact of Tax Treaties on International Mobility of Work in the Republic of North Macedonia
Chapter 23: The Impact of Tax Treaties on International Mobility of Work in Norway
Chapter 24: The Impact of Tax Treaties on International Mobility of Work in Portugal
Chapter 25: The Impact of Tax Treaties on International Mobility of Work in the Slovak Republic
Chapter 26: The Impact of Tax Treaties on International Mobility of Work in Slovenia
Chapter 27: The Impact of Tax Treaties on International Mobility of Work in South Africa
Chapter 28: The Impact of Tax Treaties on International Mobility of Work in Spain
Chapter 29: The Impact of Tax Treaties on International Mobility of Work in Sweden
Chapter 30: The Impact of Tax Treaties on International Mobility of Work in Switzerland
Chapter 31: The Impact of Tax Treaties on International Mobility of Work in Ukraine
Chapter 32: The Impact of Tax Treaties on International Mobility of Work in the United Kingdom
Chapter 33: The Impact of Tax Treaties on International Mobility of Work in the United States