The 2025 Update to the OECD Model Tax Convention

Abstract

The 2025 Update to the OECD Model Tax Convention provides a comprehensive revision of the existing treaty framework aimed at addressing contemporary challenges in international taxation. Approved by the Committee on Fiscal Affairs and the OECD Council, this update incorporates significant changes to enhance clarity and establish fair tax practices among contracting states. Key modifications include provisions for fiscal transparency, adjustments to the allocation of taxing rights, and guidelines for the treatment of interest and royalties between connected entities. The update is intended to facilitate cross-border investment, prevent tax avoidance, and promote cooperation between nations in the regulation of international tax matters. The document serves as a vital resource for policymakers, tax practitioners, and international businesses navigating the complexities of global taxation.