OECD Has Updated Model Tax Convention for 2025
The latest framework addresses cross-border tax negotiation challenges and worker mobility issues.
Updated on Sept. 30, 2026 in Remote Work
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The OECD has published its updated 2025 Model Tax Convention on Income and on Capital. This framework provides updated guidelines to help jurisdictions manage cross-border tax reporting and remote work complexities.
Why it matters
As global workforce mobility increases, the updated convention offers standardized language to assist member countries in navigating complex tax-reporting requirements. These modifications aim to harmonize how nations handle cross-border negotiations.
The 2025 update modifies Article 5 to clarify worker mobility reporting and adds new language to Article 25. These sections serve as the primary framework for tax negotiations across all participating member jurisdictions.
The players
OECD
The Organisation for Economic Co-operation and Development is an international forum that works with governments to develop evidence-based standards and policy solutions.
OECD Council
The Council is the organization's highest decision-making body, consisting of representatives from all member countries who oversee strategic direction.
The details
The revisions were approved by the OECD Council and incorporate specific guidance regarding remote work and transfer pricing. These changes are designed to streamline the administrative process for tax authorities and mobile employees alike.
Timeline
The OECD Council approved changes to the convention in November 2025.
The updated tax convention was officially published on September 30, 2026.
Market Landscape
The OECD Model Tax Convention on Income and on Capital serves as the primary benchmark for bilateral tax treaties globally. This update reinforces the organization's role in aligning national tax policies with the realities of modern, decentralized global labor markets.
These updates may eventually lead to clearer tax obligations for employees who work remotely across national borders. Multinational companies may also see shifts in how they calculate tax liability and report mobile worker income.
The takeaway
The 2025 updates reflect a necessary modernization of international tax standards to account for the rise of remote and borderless employment. Professionals working internationally should monitor how their home countries incorporate these guidelines into local tax law.
Further reading
For more information on how global labor trends are affecting international policy, see the Remote Work section.
Source note: This article includes information reported by Bloomberglaw.
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