A reflection on the future of corporate tax residency in the age of remote work and mobility of individuals

Abstract

The normalization and popularization of remote work in the post-pandemic era is likely to generate multiple consequences in the application of tax rules. In particular, the increased mobility of individuals is expected to affect the outcome of applying corporate tax residence rules based on the place from which an entity is directed and/or managed (both domestically and under tax treaties), thereby creating new opportunities for tax planning. This chapter aims to analyze the difficult coexistence between individual mobility and these residence rules, reflecting on the future of corporate tax residence.