CBS Nordic Tax Seminar on Remote Work and Global Mobility
When does a home office become a permanent establishment? Nordic perspectives after the 2025 OECD Commentary update
Råvarebygningen, Porcelænshaven 22
2000 Frederiksberg
Room: Rs20
About
Event Description:
Remote and hybrid work have transformed how businesses organise cross-border work. At the same time, they have created one of the most important and uncertain questions in international tax: when can an employee’s home office become the employer’s permanent establishment?
The 2025 update to the OECD Model Commentary addresses, for the first time in more detail, when an employee’s home may constitute a place of business for the employer. The update raises important questions around working time, employer requirements, commercial reasons, expense coverage, and whether the home office is effectively at the employer’s disposal.
Yet how these principles will be interpreted and applied across the Nordic countries remains unsettled. This seminar brings together perspectives from the Nordic region to discuss how Denmark, Sweden, Norway, Iceland, and Finland approach the home office permanent establishment question in practice.
Programme:
13:00 Welcome
- Speakers:
Pia Bramming, Head of Department, Department of Business Humanities and Law, Copenhagen Business School
Peter Koerver Schmidt, Professor and Director, CBS LAW, Copenhagen Business School
13:10 - 13:20 Remote Work, Mobility and the Changing Architecture of International Taxation
- Speaker:
Siddhesh Rao, Postdoctoral researcher, Department of Business Humanities and Law, Copenhagen Business School; Seminar Convenor
13:20 - 14:15 Session 1: Home Offices and Permanent Establishments: Reconsidering Tax Nexus in an Era of Remote Work
- Focus:
The OECD Model Tax Convention 2025 Commentary on Article 5: place of business, the 50% working-time benchmark, facts and circumstances, commercial reasons, preparatory or auxiliary activities, and Nordic administrative approaches. - Chair:
Susi Bærentzen, Head of Tax for Denmark, TotalEnergies - Panel:
Anders Nørgaard Laursen, Professor, Department of Law, Aarhus University Christian Schwartz, Senior Manager, Global Employer Services, Deloitte Sweden; Researcher, Lund Tax Academy
Mika Nissinen, Associate Professor, Law School, University of Eastern Finland Henrik Skar, Associate Professor and Head of the Tax Law Research Group, Faculty of Law, University of Bergen
Gunnar Páll Baldvinsson, Assistant Professor, Faculty of Law, University of Iceland
14:15 - 14:30 Coffee and Nordic Tax Research Showcase in the lobby
14:30 - 15:20 Session 2: Profit Attribution to Remote-Work Permanent Establishments: Functional Analysis, Transfer Pricing and Tax Controversy
- Focus:
From nexus to consequences: Articles 7 and 9, functional analysis, attribution of profits, documentation, MAP and dispute risk. - Chair:
Siddhesh Rao, Postdoc, CBS LAW, Copenhagen Business School; Seminar Convenor - Panel:
Arne Møllin Ottosen, Partner and Head of the Tax Law Group, Kromann Reumert
Susi Bærentzen, Head of Tax for Denmark, TotalEnergies
Mathias Kjærsgaard Larsen, Attorney-at-Law, Partner, Plesner
Heidi Vinther Hjelmgaard, Head of Employment Tax, A.P. Møller-Maersk
15:20 - 15:35 Coffee and Nordic Tax Research Spotlight
15:35 - 16:20 Session 3: Cross-Border Remote Work: Employment Taxation, the 183-Day Rule and Employer Obligations
- Focus:
Article 15 and the 183-day rule; distinguishing employment-income taxation from the Article 5 home-office PE analysis; the economic-employer question; frontier-worker arrangements; social-security coordination; employer compliance and remote-work policies. - Chair:
Anders Nørgaard Laursen, Professor, Department of Law, Aarhus University - Panel:
Lærke Hesselholt, Tax Partner, International Tax, Grant Thornton
Heidi Vinther Hjelmgaard, Head of Employment Tax, A.P. Møller-Maersk
Fredrik Lundgren, Partner, Global Mobility, KPMG Acor Tax, Denmark
Gunnar Páll Baldvinsson, Assistant Professor, Faculty of Law, University of Iceland
16:20 - 16:50 Session 4: Remote Work, Mobility and Tax Coordination: Towards Greater Legal Certainty in the Nordic Countries
- Focus:
Does the OECD Model Tax Convention 2025 provide a workable common framework for the Nordic countries, and where would clearer guidance, greater administrative coordination or common Nordic approaches materially improve certainty for employers and cross-border workers? - Chair:
Peter Koerver Schmidt, Professor and Director, CBS LAW, Copenhagen Business School - Panel:
Mika Nissinen, Associate Professor, Law School, University of Eastern Finland
Henrik Skar, Associate Professor and Head of the Tax Law Research Group, Faculty of Law, University of Bergen
Susi Bærentzen, Head of Tax for Denmark, TotalEnergies
Arne Møllin Ottosen, Partner and Head of the Tax Law Group, Kromann Reumert
Mathias Kjærsgaard Larsen, Attorney-at-Law, Partner, Plesner
16:50 - 17:00 Key takeaways and closing remarks
- Speakers:
Siddhesh Rao, Postdoctocral researcher, Department of Business Humanities and Law, Copenhagen Business School; Seminar Convenor
Peter Koerver Schmidt, Professor and Director, CBS LAW, Copenhagen Business School
17:00 Networking reception
Questions:
Academic Coordination
Siddhesh Rao
Postdoctoral Researcher, Department of Business Humanities and Law, Copenhagen Business School · sir.bhl@cbs.dk
The 2026 edition of the seminar is organised in connection with the collaborative research project “The Nordic Home Office Permanent Establishment: A Comparative Analysis of Administrative Practice in Light of the 2025 OECD Commentary Update”, supported by the Nordic Tax Research Council (NTRC/NSFR).
Certificate of Participation
Participants attending the CBS Nordic Tax Seminar will receive a digital Certificate of Participation stating the seminar date and number of teaching hours. The certificate may be used as documentation for continuing professional education, including for Danish lawyers and trainee lawyers, subject to the applicable rules and requirements of the relevant professional body.
For Danish lawyers and trainee lawyers
Participation in the seminar may count towards mandatory continuing professional education under the applicable Danish rules. Eligibility is subject to the requirements in force and the individual assessment under those rules.
Photography Notice
Please note that we will take photographs during the event. If you prefer not to be photographed, please avoid the camera where possible and/or inform Ms Linnea Doris Maagesø at ldm.bhl@cbs.dk. Photographs may be used to communicate and promote the activities of the Department of Business Humanities and Law, Copenhagen Business School.