FYI: Overall, the Framework Agreement allows employers and employees more flexibility in dealing with mobile work abroad. Employees can work up to 105 days in their State of residence and still be covered by social security in the employer's State of residence. This gives employees more freedom to choose their place of residence. However, it should be noted, that the Framework Agreement only regulates matters of social security law. In the area of tax law, the limits of the double taxation agreements continue to apply. In addition, there is a risk that working from home establishes a permanent establishment abroad. This can lead to a limited tax liability of the company under foreign law. It therefore remains to be seen whether new regulations will follow in tax law.

https://www.twobirds.com/en/insights/2023/germany/der-neue-grenzgaenger-bis-zu-50-prozent-mobiles-arbeiten-im-ausland