Key OECD changes to Model Tax Convention on remote work and natural resources

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Key OECD changes to Model Tax Convention on remote work and natural resources

International tax update

December 02, 2025

Global
Global
Global
The OECD has released its 2025 update to the Model Tax Convention, introducing significant changes to address cross-border tax challenges.

In this briefing, our Global Tax Team explores how the new rules clarify when remote work arrangements may create a Permanent Establishment, what strengthened source-country taxing rights mean for natural resource activities, and how updates to dispute resolution and transparency provisions aim to improve certainty and fairness in cross-border taxation.

For more information on the updates to the Model Tax Convention, please contact a member of our Global Tax Team listed at the bottom of the full article, or your usual Eversheds Sutherland contact.

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