Covid-19 impact on international tax law: Italy signed agreements with France and Switzerland on taxation of cross-border and frontier workers cases

The agreements read as follows:

“exceptionally and provisionally, for the application of paragraphs 1 and 4 of Article 15 (related to income from employment) of the double tax treaty, it is accepted that, due to the measures to prevent the spread of COVID-19, days worked in the State of residence at home on behalf of an employer located in the other Contracting State shall be deemed as days worked in the State in which the individual, in the absence of such measures, would have exercised its employment for which salaries are received”.