OECD updates commentary on permanent establishment rules, marking new era of remote working

The update provides helpful guidance for businesses regarding the tax implications of remote work and permanent establishment risk, as detailed by Denis Larkin, Priscilla Tang and Tom Newsome.

The Organisation for Economic Cooperation and Development (OECD) has released updates to its Model Tax Convention Commentary, clarifying permanent establishment (PE) rules for employees working remotely from their home countries. Remote work requests have for some time created uncertainty about tax risks for employers when employees work from a different country to where they are primarily employed. Specifically, employers have had to grapple with questions about whether an employee working...

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Authors: Denis Larkin, Priscilla Tang,

Published Date: 03 December 2025