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What happened?
On November 19, 2025, the OECD released updates to the OECD Model Treaty and Commentary. The updates provide guidance related to cross-border remote work in the context of permanent establishment, as well as the taxation of certain income related to natural resource extraction.
Why is it relevant?
While cross-border remote work arrangements have proliferated in recent years, there has been a dearth of guidance on how to address such arrangements from a cross-border tax perspective. The OECD Model Treaty and Commentary may influence how such arrangements are viewed by tax authorities, courts, and practitioners.
Action to consider
Businesses should consider how these changes to OECD Model Treaty and Commentary may affect existing cross-border remote work arrangements and the guidelines provided to remote workers.
2025 updates to the OECD Model Treaty and Commentary released addressing cross-border remote work arrangements
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