One of the most basic principles in international tax law, the permanent establishment (PE), is under strain amid the surge in hybrid and remote work options. For years, the test under Article 5 of the OECD Model Tax Convention was based on the notion of a "place of business" that is fixed and distinct. This model was tested during the COVID-19 pandemic as employees started working remotely in workplaces across the country, and it has already proved to be challenging: employees can now carry out