Coronavirus (COVID-19)—what are the potential tax consequences of working remotely, including cross-border employment tax issues?

As a result of measures to slow down the spread of coronavirus (COVID-19), many countries including the UK are in lockdown. For employees, this often means that travel to and from work has been restricted so that only those who cannot work remotely are allowed to travel to work and then only where travelling to work is absolutely necessary—for instance, key workers like healthcare staff. Consequently, many employees are working remotely, whether from their home or from another country in which they find themselves during a lockdown. Some employers chose to require their employees to work from home even before any lockdown was announced. Employees who are perhaps seconded to other countries badly affected by the virus may already have relocated back to their home or may wish to do so, or may have been requested to do so by their employers. These scenarios may give rise to potential tax issues.

Where an employee working remotely from home works in a different jurisdiction to their normal workplace, this may affect the taxing rights of the countries concerned. This may particularly affect cross-border secondees or workers who commute from one country to another (particularly in continental Europe). Much will depend on the length of time that a person spends working in a particular country and on the particular tax rules of the jurisdiction concerned. From a