The OECD has released an update to the Model Tax Convention on Income and on Capital, providing new and detailed guidance on short-term cross-border remote work and on the taxation of income from natural resource extraction. The update, approved by the OECD Council, aims to provide greater certainty for governments and businesses worldwide.
The OECD Model Tax Convention on Income and on Capital (the OECD Model) is a flagship publication used by both OECD Members and non-Members as a basis for negotiating, applying and interpreting bilateral tax treaties. It plays a key role in removing tax-related barriers to cross border trade and investment, helping to prevent tax evasion and avoidance, and providing a means to settle on a uniform basis the most common problems that arise in the field of international juridical double taxation. This document sets out the changes introduced in the 2025 update to the OECD Model, which were approved by the OECD Council on 18 November 2025. The update reflects the latest developments in international taxation and offers enhanced guidance for the interpretation and application of tax treaties. These changes will be incorporated into the forthcoming revised condensed and full editions of the OECD Model, to be published in 2026.
Join the OECD’s tax treaty team for a webinar on the latest updates to the OECD Model Tax Convention on Income and on Capital (the OECD Model), a flagship publication used by governments and taxpayers as the basis for the negotiation and interpretation of bilateral double tax treaties.
As remote work crosses borders, where does tax follow? Explore how OECD guidance and the OECD Model Tax Convention help businesses navigate taxable presence and apply international tax rules in a changing, digitalised economy.
