OECD ADAPTS TO REMOTE WORK ECONOMY
HOME OFFICES AS POTENTIAL PERMANENT ESTABLISHMENTS IN REMOTE WORK ERA
On November 19, 2025, the Organization for Economic Co-operation and Development (“OECD”) released an update to the OECD Model Tax Convention on Income and on Capital (the “2025 Update”).
Among the changes are important clarifications to the Commentary on Article 5, dealing with the meaning of Permanent Establishment (“PE”) – and more specifically directed at helping determine when an individual’s home office may constitute a PE of the enterprise engaging the worker.
In a world increasingly shaped by remote work, changes like these are timely and likely only the beginning of further developments – and tax audits!
Tagged in:
Contractors or Agents
Employer Health Tax
Organization for Economic Co-operation and Development
Permanent Establishment
Tax Audits
Last modified on