OECD Model Tax Convention 2025 Update - Remote Working, Permanent Establishments & Key Treaty Developments

Introduction

The OECD published the full edition of its 2025 Model Tax Convention on 30 September 2026, incorporating the update approved in November 2025. It provides important guidance for advisers dealing with international business activities, particularly cross-border remote working and permanent establishment (PE) exposure.

This webinar will explain the principal developments through short, worked examples, with the greatest emphasis on remote working and PE risk, supported by a concise overview of the other treaty changes.

Ideal for tax practitioners, accountants and lawyers, this webinar will include a practical checklist to help delegates identify arrangements requiring further review.

What You Will Learn

This webinar will cover the following:

• The revised Article 5 home-office guidance: the 50% working-time indicator, the relevant 12-month measurement period and why the indicator does not automatically determine PE status
• The significance of a commercial reason for working overseas, including the distinction between personal relocation and activities that facilitate the employer’s business
• Practical examples involving employees working abroad, overseas customer-facing roles and owner-managed businesses, including when a separate dependent-agent PE analysis is required
• Article 9 clarifications concerning debt and equity, domestic interest deductibility restrictions and corresponding adjustments
• Other key developments: the optional treaty provision for extractive activities, Article 25’s interaction with GATS dispute procedures and Article 26 guidance on information use and confidentiality
• Applying the update to existing arrangements: the relevance and limits of later commentary, the applicable treaty wording, and country reservations, observations and local practice