OECD: 2025 update to OECD Model Tax Convention

Providing new and detailed guidance on short-term cross-border remote work and on the taxation of income from natural resource extraction

The Organisation for Economic Co-operation and Development (OECD) today released the 2025 update to the OECD Model Tax Convention on Income and on Capital, providing new and detailed guidance on short-term cross-border remote work and on the taxation of income from natural resource extraction.

As explained in the related OECD release, the changes, which aim to enhance tax certainty and support fair and efficient cross-border business taxation, include:

Remote working: Clear guidance on how cross-border “home office” arrangements are treated under tax treaties, providing certainty for employers and employees
Natural resources: A new alternative tax treaty provision to ensure that income from activities connected with natural resources extraction is taxed where it occurs, reinforcing source-country rights and supporting resource-endowed developing economies
Other improvements: Additional refinements to enhance consistency in treaty interpretation and strengthen tax certainty

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OECD: 2025 update to OECD Model Tax Convention

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