When does a home office become a permanent establishment? Nordic perspectives after the 2025 OECD Commentary update
Remote and hybrid work have transformed how businesses organise cross-border work. At the same time, they have created one of the most important and uncertain questions in international tax: when can an employee’s home office become the employer’s permanent establishment?
The 2025 update to the OECD Model Commentary addresses, for the first time in more detail, when an employee’s home may constitute a place of business for the employer. The update raises important questions around working time, employer requirements, commercial reasons, expense coverage, and whether the home office is effectively at the employer’s disposal.
Yet how these principles will be interpreted and applied across the Nordic countries remains unsettled. This seminar brings together perspectives from the Nordic region to discuss how Denmark, Sweden, Norway, Iceland, and Finland approach the home office permanent establishment question in practice.
Programme
| 13:00 - 13:10 | Welcome Pia Bramming, Head of Department, Department of Business Humanities and Law, Copenhagen Business School |
| 13:10 - 13:20 | Remote Work, Mobility and the Changing Architecture of International Taxation Speaker: |
| 13:20 - 14:15 | Session 1: Home Offices and Permanent Establishments: Reconsidering Tax Nexus in an Era of Remote Work Focus: |
| 14:15 - 14:30 | Coffee and Nordic Tax Research Showcase in the Lobby |
| 14:30 - 15:20 | Session 2: Profit Attribution to Remote-Work Permanent Establishments: Functional Analysis, Transfer Pricing and Tax Controversy Focus: |
| 15:20 - 15:35 | Coffee and Nordic Tax Research Showcase in the Lobby. |
| 15:35 - 16:20 | Session 3: Cross-Border Remote Work and the Allocation of Taxing Rights over Employment Income Focus: |
| 16:20 - 16:50 | Session 4: Remote Work, Mobility and Tax Coordination: Towards Greater Legal Certainty in the Nordic Countries Focus: |
| 16:50 - 17:00 | Key takeaways and closing remarks Speakers: |
| 17:00 | Networking reception |
This seminar is organised in connection with the collaborative research project “The Nordic Home Office Permanent Establishment: A Comparative Analysis of Administrative Practice in Light of the 2025 OECD Commentary Update”, supported by the Nordic Tax Research Council (NTRC/NSFR).
Certificate of Participation
Participants attending the CBS Nordic Tax Seminar 2026 will receive a digital Certificate of Participation stating the seminar date and number of teaching hours. The certificate may be used as documentation for continuing professional development, subject to the requirements of the relevant professional body.
Seminar Convenor: Siddhesh Rao, Postdoc, CBS LAW, Copenhagen Business School · sir.bhl@cbs.dk