A changing working environment based on digitalization has supported hybrid working. Employees are no longer required to work only at their traditional workplace at a company's headquarters, but can work from any place where a power socket, a laptop, a cell phone, and Wi-Fi are available. The impact of the COVID-19 pandemic and unprecedented restrictions on travelling and international assignments have reinforced this development and triggered a sustaining change in business behavior. If individuals dependent on an enterprise perform their work in countries other than the residence country of their employer the question arises whether such “digital nomads" could create a nexus in the source state by constituting a permanent establishment for the enterprise and thus trigger corresponding tax obligations. In this article, Stefan Bendlinger argues that this should not be the case.
