Cross-border home working challenges the conventional concept of permanent establishment, which developed around identifiable commercial premises. Digital technology now permits individuals to perform sustained and economically significant functions for an enterprise in a jurisdiction where the enterprise has no formally established office or branch. The OECD’s 2025 Update to the OECD Model Tax Convention introduces a revised approach to this issue. Working from a home for less than 50 per cent of total working time will generally not create a place of business. Reaching that threshold does not itself establish a permanent establishment; the wider circumstances, including whether the individual’s presence commercially facilitates the enterprise’s business in the host State, remain important. Using Australia as a case study, the discussion considers how this approach interacts with domestic law, tax treaties, withholding taxes and profit-attribution rules. It evaluates when sustained home working should establish a sufficient business presence in the host State and how jurisdictions might implement the OECD’s approach without treating personal relocation, employee retention or reduced office costs as sufficient in themselves.
SPEAKER
Dr Christina Allen
Senior Lecturer
Curtin University
Dr Christina Allen is a senior lecturer at Curtin University in Western Australia, a fellow of the Advanced Higher Education, a executive committee member of SHAPE Futures and the academic representative of the Taxation Centre of Excellence at CPA Australia. She was awarded her PhD and master’s degrees in taxation law from the University of Western Australia and graduated as the valedictorian from the Faculty of Business and Law of Edith Cowan University. She has received numerous awards, scholarships and prizes for academic excellence, including the prestigious Prime Minister’s Australia Asia Endeavour Award, and was the finalist for the Leadership in Government award sponsored by the Chartered Accountants Australia & New Zealand during her employment in the Australian Taxation Office. She widely publishes in taxation law and policy and has a particular interest in the interdisciplinary area of tax and technology. She has held visiting positions at Vienna University of Business and Economics (Austria), University of Cape Town (South Africa), Digital Finance Cooperative Research Centre (Sydney), York University (Canada) and Victoria University of Wellington (New Zealand).
CHAIR
Dr Vincent Ooi
Assistant Professor of Law
Singapore Management University
DETAILS
Date: 11 September 2026, Friday
Time: 12.30pm to 1.30pm [Registration commences from 12pm and Lunch will be provided]
Venue: Training Room 1 (Transcend), Tax Academy of Singapore Hub, #01-03, Revenue House [55 Newton Rd, Singapore 307987]
REGISTRATION
Registration Fees:
For Public - $50 (subject to prevailing GST)
Please click HERE to register.
For SMU Staff and Students - Complimentary
Please click HERE to register.
Registration closes on 1 September 2026, 12pm SGT or when the workshop is fully subscribed, whichever is earlier.
ORGANISERS
About Singapore Tax Academy Research Initiative (STARI)
The Singapore Tax Academy Research Initiative (STARI) conducts leading tax law research in a rapidly developing international tax landscape, while also building domestic tax research capacity, developing strong academic networks, and bringing the best in international tax thought-leadership to the tax profession in Singapore. In addition to its research activities, STARI provides training in academic research and writing, and works with the world’s best tax law academics to develop tax professionals.
https://ccla.smu.edu.sg/stari
About Tax Academy of Singapore
The Tax Academy of Singapore is a not-for-profit institution set up by the Inland Revenue Authority of Singapore in collaboration with the international accounting firms – Deloitte & Touche, Ernst & Young, KPMG and PricewaterhouseCoopers, the Singapore Chartered Tax Professionals, the Institute of Singapore Chartered Accountants and the Law Society of Singapore.
As a leading hub for tax excellence and a network of networks, Tax Academy collaborates with leaders in the industry, academia and the government to develop and deliver structured tax training programmes, regular seminars and conferences. Through these platforms, tax professionals can stay current with global developments while enhancing their professional competency, knowledge and capabilities. By fostering exchanges between industry experts, academics and government officials from both local and international spheres, Tax Academy cultivates an environment of continuous learning and knowledge sharing.
https://www.taxacademy.sg
