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OECD commentary on home office

Implications for permanent establishment and workforce strategy

OECD commentary on home office

Remote work and cross-border tax implications: What’s changing

The organization for economic co‑operation and development (OECD) updated commentary on home office arrangements signals a shift in how permanent establishment risk is evaluated in a remote work environment. While the guidance introduces additional clarity, it also reinforces that workforce decisions may have broader tax implications across jurisdictions.

The OECD has outlined new considerations around when remote work may create a taxable presence, including a working time threshold and a greater focus on the nature of activities performed. This reflects a move away from location as the sole factor, toward how employees contribute to business operations.

Why it matters

As remote and hybrid work models continue to expand, organizations may face increased complexity in aligning workforce flexibility with tax and compliance frameworks. Without clear alignment, risk may arise in ways that are not immediately visible.

Organizations may need to revisit how remote work is structured, governed, and monitored in light of evolving guidance. This includes evaluating workforce arrangements, policy frameworks, and visibility into employee location.

Application of OECD guidance may vary by jurisdiction, with further developments expected. Organizations will need to remain responsive as the regulatory landscape continues to evolve.

Dive into our thinking:

OECD commentary on home office

Why you should be following it closely

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Meet our team

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Kshipra Thareja
Principal, Tax, Global Mobility Services, KPMG US
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Daida Hadzic
Director, Washington National Tax, Global Mobility Services, KPMG LLP

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