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This report of the European Region of IFA evaluates the tax and social security implications of frontier workers in Europe. The exact meaning and scope of “frontier worker” differ in tax law and social security law. Several relatively old tax treaties contain special tax provisions attuned to the cross-border situation of frontier workers that deviate from the general allocation rules for employment income (article 15 of the OECD Model). The common characteristics of these special treaty provisions of daily return and geographical proximity may lead to unconscious tax biases in a changing landscape of digitalization and globalization. Tax treaties - primarily drafted at a time when physi...
This work covers the complex legal and social facts which the frontier workers are faced with. Although European law coordinates the differing legislation of the Member States for the benefit of the frontier workers, it cannot eliminate the existing national differences in social and tax law.