The challenges brought forth by the Covid-19 pandemic have given rise to new issues facing international tax rules and conventions. The restrictions on the mobility of individuals may force a new perspective in terms of tax residency criteria, and the development of professional activities from a distance, through the use of digital means, should also be reflected upon with regards to what constitutes a permanent establishment. If addressed soon, these questions could help prevent future litigation and aid in the post-pandemic period of economic recovery.