Unpacking the Home Office Permanent Establishment Guidance under the 2025 Update to the OECD Model

Key Points

• This article aims to analyze the new guidance on home offices as permanent establishments in light of the 2025 OECD Model updates.
• Critical examination of the new guidance
• Identification of strengths and weaknesses
• Assessment of practical implications for existing treaties
• Strengths include clearer definitions of home office scenarios.
• Weaknesses highlight potential ambiguities in interpretation.
• Practical implications suggest revisions may be needed for existing treaties.