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June 27, 2026

This official document details the 2025 Update to the OECD Model Tax Convention, which implements major changes to international tax treaty standards. Key revisions include adding a new clause to Article 25 regarding dispute resolution coordination with the General Agreement on Trade in Services (GATS), and extensive updates to the Article 5 Commentary to address modern remote working arrangements by establishing a general 50% working time threshold and commercial justification test for home office Permanent Establishments (PE). The update also introduces an optional, lower PE threshold provision for the natural resource extractives sector, clarifies transfer pricing and thin capitalization rules for financial transactions under Article 9 in alignment with BEPS Action 4, signposts dispute mechanisms for Amount B, and expands data usage allowances under exchange of information rules in Article 26.

The 2025 Update to the OECD Model Tax Convention

Executive summary

Changes to be included in the 2025 Update to the Model Tax Convention

A. Changes to the Introduction

B. Changes to the Articles

Article 25

C. Changes to the Commentaries

Commentary on Article 1

Commentary on Article 2

Commentary on Article 3

Commentary on Article 4

Commentary on Article 5

Commentary on Article 6

Commentary on Article 7

Commentary on Article 8

Commentary on Article 9

Commentary on Article 10

Commentary on Article 11

Commentary on Article 12

Commentary on Article 13

Commentary on Article 15

Commentary on Article 16

Commentary on Article 17

Commentary on Article 18

Commentary on Article 19

Commentary on Article 20

Commentary on Article 21

Commentary on Article 22

Commentary on Articles 23 A and 23 B

Commentary on Article 24

Commentary on Article 25

Commentary on Article 26

Commentary on Article 29

D. Changes to the Positions of Non-Member Economies

Introduction

Positions on Article 1 and its Commentary

Positions on Article 2 and its Commentary

Positions on Article 3 and its Commentary

Positions on Article 4 and its Commentary

Positions on Article 5 and its Commentary

Positions on Article 6 and its Commentary

Positions on Article 7 and its Commentary

Positions on Article 8 and its Commentary

Positions on Article 9 and its Commentary

Positions on Article 10 and its Commentary

Positions on Article 11 and its Commentary

Positions on Article 12 and its Commentary

Positions on Article 13 and its Commentary

Positions on Article 15 and its Commentary

Positions on Article 16 and its Commentary

Positions on Article 17 and its Commentary

Positions on Article 18 and its Commentary

Positions on Article 19 and its Commentary

Positions on Article 20 and its Commentary

Positions on Article 21 and its Commentary

Positions on Article 22 and its Commentary

Positions on Articles 23 A and 23 B and its Commentary

Positions on Article 24 and its Commentary

Positions on Article 25 and its Commentary

Positions on Article 26 and its Commentary

Positions on Article 29 and its Commentary

Positions on Article 30 and its Commentary

Positions on Article 32 and its Commentary

Table of contents