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In this briefing, our Global Tax Team explores how the new rules clarify when remote work arrangements may create a Permanent Establishment, what strengthened source-country taxing rights mean for natural resource activities, and how updates to dispute resolution and transparency provisions aim to improve certainty and fairness in cross-border taxation. For more information on the updates to the Model Tax Convention, please contact a member of our Global Tax Team listed at the bottom of the full article, or your usual Eversheds Sutherland contact. The materials on the Eversheds Sutherland website are for general information purposes only and do not constitute legal advice. While reasonable care is taken to ensure accuracy, the materials may not reflect the most current legal developments. Eversheds Sutherland disclaims liability for actions taken based on the materials. Always consult a qualified lawyer for specific legal matters. To view the full disclaimer, see our Terms and Conditions or Disclaimer section in the footer. Services Tax Key contacts Robert Waterson Partner United Kingdom Ben Jones Partner United Kingdom Elena Teletin Partner Bucharest, Romania Robert S. Chase II Partner Washington, DC, United States Chantal Presilli Partner Rotterdam, Netherlands \| Amsterdam, Netherlands Dr. Lars H. Haverkamp, LL.M. 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All rights reserved. Eversheds Sutherland is a provider of legal and other services operating through various separate and distinct legal entities. For further information about these entities and Eversheds Sutherlands' structure please see the Legal Notice page of this website. Eversheds Sutherland is the name and brand under which the members of Eversheds Sutherland Limited (Eversheds Sutherland (International) LLP and Eversheds Sutherland (US) LLP) and their respective controlled, managed and affiliated firms and the members of Eversheds Sutherland (Europe) Limited (each an "Eversheds Sutherland Entity" and together the "Eversheds Sutherland Entities") provide legal or other services to clients around the world. Eversheds Sutherland Entities are constituted and regulated in accordance with relevant local regulatory and legal requirements and operate in accordance with their locally registered names. The use of the name Eversheds Sutherland, is for description purposes only and does not imply that the Eversheds Sutherland Entities are in a partnership or are part of a global LLP. The responsibility for the provision of services to the client is defined in the terms of engagement between the instructed firm and the client. For further information about these Eversheds Sutherland Entities and Eversheds Sutherlands’ structure please see the Legal Notices page of this website. For information on Konexo please also see the Legal Notices page of this

Key OECD changes to Model Tax Convention on remote work and natural resources

International tax update

December 02, 2025

Global

The OECD has released its 2025 update to the Model Tax Convention, introducing significant changes to address cross-border tax challenges.

In this briefing, our Global Tax Team explores how the new rules clarify when remote work arrangements may create a Permanent Establishment, what strengthened source-country taxing rights mean for natural resource activities, and how updates to dispute resolution and transparency provisions aim to improve certainty and fairness in cross-border taxation.

For more information on the updates to the Model Tax Convention, please contact a member of our Global Tax Team listed at the bottom of the full article, or your usual Eversheds Sutherland contact.

The materials on the Eversheds Sutherland website are for general information purposes only and do not constitute legal advice. While reasonable care is taken to ensure accuracy, the materials may not reflect the most current legal developments. Eversheds Sutherland disclaims liability for actions taken based on the materials. Always consult a qualified lawyer for specific legal matters. To view the full disclaimer, see our Terms and Conditions or Disclaimer section in the footer.

Robert Waterson

Partner

United Kingdom

Ben Jones

Partner

United Kingdom

Elena Teletin

Partner

Bucharest, Romania

Robert S. Chase II

Partner

Washington, DC, United States

Chantal Presilli

Partner

Rotterdam, Netherlands | Amsterdam, Netherlands

Dr. Lars H. Haverkamp, LL.M. (Christchurch)

Partner

Dusseldorf, Germany

Robert Dever

Partner

Dublin, Ireland

Rafael Moll de Alba

Partner

Luxembourg, Luxembourg

Zoya Zalmai

Partner

Amsterdam, Netherlands

Antonio Cuéllar

Partner

Madrid, Spain

Sebastiano Sciliberto

Executive Partner

Rome, Italy

Torsti Lakari

Partner

Helsinki, Finland

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© Eversheds Sutherland 2026. All rights reserved. Eversheds Sutherland is a provider of legal and other services operating through various separate and distinct legal entities. For further information about these entities and Eversheds Sutherlands' structure please see the Legal Notice page of this website.

Eversheds Sutherland is the name and brand under which the members of Eversheds Sutherland Limited (Eversheds Sutherland (International) LLP and Eversheds Sutherland (US) LLP) and their respective controlled, managed and affiliated firms and the members of Eversheds Sutherland (Europe) Limited (each an "Eversheds Sutherland Entity" and together the "Eversheds Sutherland Entities") provide legal or other services to clients around the world. Eversheds Sutherland Entities are constituted and regulated in accordance with relevant local regulatory and legal requirements and operate in accordance with their locally registered names. The use of the name Eversheds Sutherland, is for description purposes only and does not imply that the Eversheds Sutherland Entities are in a partnership or are part of a global LLP. The responsibility for the provision of services to the client is defined in the terms of engagement between the instructed firm and the client. For further information about these Eversheds Sutherland Entities and Eversheds Sutherlands’ structure please see the Legal Notices page of this website. For information on Konexo please also see the Legal Notices page of this

Key OECD changes to Model Tax Convention on remote work and natural resources

International tax update

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