“It’s Complicated”: The Problematic Interplay between Digital Nomads, the EU Minimum Taxation Directive and the Proposed Unshell Directive

Abstract

In this article, the author discusses the potential impact of the EU Minimum Taxation Directive (2022/2523) and the Proposed Unshell Directive on digital nomadism. In addition to analysing these directives, she discusses the OECD Global Anti-Base Erosion Model Rules, in particular new administrative guidance issued in July 2023.