The OECD Model Tax Convention 2025 Update

Session 1: Understanding the update and its practical relevance

• The distinction between changes to the Model Articles and changes to the Commentary; the relevance of updated Commentary to existing treaties; and the importance of treaty wording, country reservations and observations.

Session 2: Remote working and home-office PEs

• The working-time indicator, the relevant twelve-month measurement period and the commercial reasons for working in a particular country. Applying the guidance to personal relocation, customer-facing activities and regional responsibilities, while recognising that the 50% indicator is not a universal exemption from PE risk.
• Short scenarios will illustrate how differences in working patterns and business responsibilities can change the assessment.

Session 3: Founders and owner-managed businesses

• The particular considerations where an individual is the sole or principal person conducting the enterprise’s business.
• A founder relocation scenario will illustrate the issues and the need to consider corporate residence and dependent-agent exposure separately.

Session 4: Article 9 and intragroup financing

• Debt/equity characterisation and the relationship with the OECD Transfer Pricing Guidelines; the distinction between arm’s-length profit allocation and domestic interest deduction restrictions; and the circumstances in which corresponding adjustment relief may be unavailable.
• A short financing example will demonstrate why an arm’s-length interest rate does not, by itself, resolve the deductibility analysis.

Session 5: Other treaty developments

• A concise overview of the optional provision for extractive activities, the new Article 25(6) addressing interaction with the General Agreement on Trade in Services, and the revised Article 26 guidance on information exchange.

Session 6: Practical review checklist

• Bringing the analysis together: working arrangements, commercial rationale, responsibilities, treaty provisions, financing documentation and evidence to retain.

Session 7: Questions and discussion 

 Delegate materials

• Presentation slides, the practical scenarios discussed during the session and a concise checklist for reviewing cross-border working arrangements and financing structures

Redcliffe's course trainer is the CEO and Tax Advisor at a tax consultancy / advisory firm. He advises internationally active businesses and individuals on UK and cross-border tax, with a particular focus on permanent establishment risk, corporate residence/POEM, treaty positions and documentation, and cross-border structuring (including withholding tax considerations and transfer pricing).

The trainer lectures in International Taxation (CIOT/ADIT context) and has held senior tax leadership and advisory roles, including Head of Tax for the Diacron Group and consulting/advisory work with other International Tax firms (including Bain & Company). He has worked across multiple jurisdictions, including the UK, Italy, the US and Costa Rica, and brings a practitioner-led, case-driven approach that is grounded in real client scenarios.

By the end of the session, delegates should be able to:

• Identify the principal developments relevant to cross-border working and financing.
• Apply the home-office guidance to contrasting factual scenarios and recognise circumstances requiring closer review.
• Distinguish arm’s-length pricing and debt characterisation from domestic deductibility restrictions and corresponding adjustment relief.
• Identify the treaty provisions, country positions and supporting evidence needed for a defensible assessment.

• Tax advisers, corporate lawyers, in-house tax professionals and finance directors advising on international operations, founder relocations or intragroup funding.
• The session will also be relevant to global mobility professionals involved in approving cross-border working arrangements.
• A basic understanding of tax treaties would be helpful.

• Cross-border working arrangements and intragroup financing continue to raise difficult questions about taxable presence, profit allocation and treaty protection.
• This session examines the principal practical developments in the OECD’s 2025 Update and how advisers should approach them when reviewing existing arrangements or proposed changes.
• Using short case studies, the course will focus on remote working, home-office permanent establishments and founders operating abroad, alongside the updated guidance on financing. It will also explain how to approach the updated Commentary in the context of the treaty actually applicable to the transaction or arrangement.