Bloomberg (Ryan Hogg), OECD Publishes Fresh Model Tax Convention After 2025 Updates:
The OECD published its updated tax convention Wednesday following a wave of guidance approved last year on issues like remote work and transfer pricing.
The Model Tax Convention on Income and on Capital 2025 outlines the framework for OECD members to engage in cross-border tax negotiations.
The Organization for Economic Cooperation and Development’s Council, which is made up from representatives of OECD member jurisdictions, approved several changes to the convention in November 2025.
Key changes include modifications to Article 5, which clarified issues related to worker mobility for tax-reporting purposes, and new approved language on Article 25, offering more options for addressing double taxation issues via transfer pricing frameworks.
- The model tax convention is an important reference point for OECD members to negotiate, apply, and interpret bilateral tax treaties.
- The convention was last updated in 2017.
- “At a time when economies and ways of working continue to evolve, the OECD Model Tax Convention remains an essential tool for promoting tax certainty, preventing double taxation, and supporting cross-border trade and investment,” said Manal Corwin, director of the OECD’s Center for Tax Policy and Administration.
