This thesis addresses the tax law challenges posed by flexible forms of employment, specifically remote working with a cross-border element. Challenges are situated within a broader conceptual framework through a brief outline of key concepts and an overview of the current OECD Model Tax Convention on Income and on Capital.
The thesis then shifts from the theoretical to the practical, providing a comparative analysis that demonstrates how certain countries used to exploit the current international tax framework for taxing employment income to advance their interests. It also presents various methods that states employ in these endeavours.
Finally, the thesis offers a range of new theoretical solutions from the perspective of adjustments to national legal regimes, as well as international tax law, that could resolve the highlighted challenges in a manner that provides appropriate legal security for workers in such forms of employment, prevents the possibility of double taxation, and simultaneously limits opportunities for aggressive tax planning.
|
