The Impact of COVID-19 Over the Tax Residence Rules for Companies and Individuals: A Latin American Approach

Revista de Administración Tributaria 2021

22 Pages Posted: 13 Aug 2021

See all articles by Omar Sebastian Cabrera

Omar Sebastian Cabrera

Universidad Externado de Colombia, Department of Law, Department of Law

Date Written: August 12, 2021

Abstract

The adoption of strict lockdowns and quarantines have been usual and common in the early outbreak of the COVID-19 pandemic and were maintained in some places of the world during 2021. In that sense, the closing of borders had a significant impact for the purposes of asserting tax residence for both individuals and companies considering the rules in Comparative Tax Law. In spite of the fact that the OECD released a couple of reports concerning this matter, the truth is that the lack of uniform regulation and the clear impossibility of applying the OECD’s tax model tiebreaker and distributive rules in all cases triggered a relevant debate over this topic, which includes Latin American countries.

Keywords: Tax Residence, Place of Effective Management, World Income Taxation, Dual Residence, Tiebreaker Rules, Double Taxation Conventions

Suggested Citation

Cabrera, Omar Sebastian, The Impact of COVID-19 Over the Tax Residence Rules for Companies and Individuals: A Latin American Approach (August 12, 2021). Revista de Administración Tributaria 2021, Available at SSRN: https://ssrn.com/abstract=3904141

Omar Sebastian Cabrera (Contact Author)

Universidad Externado de Colombia, Department of Law, Department of Law ( email )

Calle 12 No. 1-17 Este
Bogota, Bogota
Colombia
(571)3537000 (Phone)

HOME PAGE: http://https://www.uexternado.edu.co/

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