On November 19, 2025, the Organisation for Economic Co-operation and Development (OECD) published long-awaited updates to the Commentary on the Model Tax Convention (the “Commentary 2025”). The updated guidance is focused on the concept of a permanent establishment (PE) when employees work remotely from home in a country or location that is not linked to the employer, providing clarifications to the Commentary 2025 on Article 5 of the Convention.

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Fuente: KPMG