New OECD guidance re-affirms its view that an individual who becomes stranded in a foreign country may become tax resident there under that country's domestic rules but is unlikely to be resident there under the tie-breaker provisions of a double tax agreement (DTA). Individuals who have returned home from assignment overseas may regain their original residency under domestic law, but the DTA is likely to determine that they continue to be resident overseas. Jurisdictions are not obliged to follow the OECD guidance.
News Source：【OECD 2021/01/21】
