The Influence of Remote Work on the Place of Effective Management under Article 4(3) of the OECD Model: Remote Work, Remote POEM?

This article explores how remote work and decentralized management affect the place of effective management (POEM), influencing corporate tax residence. It categorizes impacts into three levels – limited, moderate and high – based on activities, and suggests solutions, from policy reforms to company measures, to mitigate POEM-related tax risks.