As a result of the COVID-19 pandemic restrictions, many cross-border workers are unable to physically perform their duties in their country of employment. This unusual situation is raising many tax issues, especially where there are cross-border elements in the equation. The exceptional circumstances of the COVID-19 crisis call for an exceptional level of coordination and co-operation between countries, notably on tax issues, to mitigate the potentially significant compliance and administrative costs for employees and employers. At the request of concerned countries, the OECD Secretariat has issued guidance on these issues based on a careful analysis of the international tax treaty rules.

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