PE developments in response to COVID-19
Germany – Austria
On 18 June 2021, the German Ministry of Finance published a new mutual agreement with Austria on their 2000 tax treaty. The mutual agreement addresses frontier workers and replaces the mutual agreement signed in January 2021. The latest mutual agreement includes a section on the application and interpretation of Article 5(1) of the treaty (fixed place of business) with respect to home office permanent establishments (PEs). Accordi…