The mobility of directors and the rise of remote work are reshaping one of the most critical concepts in international taxation: the place of effective management (POEM). For decades, POEM served as the key tie-breaker rule to resolve conflicts of dual corporate residence under tax treaties. Since the 2017 OECD Model update, however, this role has been replaced by the mutual agreement procedure (MAP), shifting the resolution of residence conflicts from a single substantive test to negotiation between tax authorities. At the same time, the digitalization of decision-making moved it to online cyberspace and has made POEM determinations more complex in practice.

This lecture explored how directors' mobility can trigger residence disputes, lead to the creation of permanent establishments, and even result in exit taxation if a company's effective management is deemed to have shifted abroad. Drawing on recent academic research and international practice, the lecture highlighted practical strategies for directors and companies to mitigate risks, ensure legal certainty, and adapt to the realities of global mobility and digital management, as well as suggests a tax policy outlook.