KPMG report: 2025 update to OECD Model Tax Convention
A KPMG report discussing the changes under the 2025 update
The Organisation for Economic Co-operation and Development (OECD) in November 2025 released the 2025 update to the OECD Model Tax Convention on Income and on Capital, which included the following changes:
- Clarification on how cross-border remote working arrangements may give rise to permanent establishments (PEs)
- Introduction of an optional provision for taxing income from natural resource extraction based on a time test
- Clarification of the application of transfer pricing rules to financial transactions
- Guidance on application of Pillar Two Amount B
Read a December 2025 report prepared by KPMG International that discusses the changes under the 2025 update.