On 8 December 2023, the Netherlands published in the Official Gazette a competent authority agreement signed with Belgium on 23 November 2023 regarding the application of Article 5 (Permanent Establishment) of the 2001 Belgium-Netherlands tax treaty in relation to employees working from home. The agreement is intended to provide clarity for employers in Belgium and the Netherlands on the elements that are particularly important when assessing whether employees working from home in their country of residence results in a permanent establishment within the meaning of Article 5 of the treaty. In this regard, the agreement refers to the OECD Commentary...