OECD Releases The 2025 Update To Its Model Treaty

The 2025 Update to the OECD Model Treaty has been released with changes being introduced to Article 25 on MAPs and its Commentary, as well as to the Commentaries on Article 5 on Permanent Establishment, Article 9 on Associated Enterprises, and Article 26 on Exchange of Information. The changes will be incorporated into the forthcoming edition of the OECD Model to be published in 2026.

On 19 November 2025, the OECD published the 2025 Update to its Model Tax Convention on Income and Capital (OECD Model) reflecting the latest developments in international taxation and offering enhanced guidance for the interpretation and application of tax treaties (the 2025 Update). Developed and negotiated during the past few years by the OECD's Working Party No.1, the 2025 Update was approved by the OECD Council on 18 November 2025 and will be incorporated into the forthcoming edition of the OECD Model to be published in 2026. It is advisable for taxpayers to thoroughly review and