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International TaxArticle·20 November 2025

2025 Update to OECD Convention

By J the App

Executive Summary

The OECD has released its 2025 update to the Model Tax Convention, on 18th November 25, a targeted but high-impact refresh that will influence treaty policy worldwide. While the changes don’t automatically alter India’s existing DTAAs, they carry strong interpretational weight, especially since Indian courts and tax authorities routinely rely on OECD Commentary. With new guidance on remote-work PE, natural-resource taxation, MAP expansion, interest-limitation alignment, and information exchange, the update signals how global treaty norms are shifting, and what Indian businesses must prepare for as cross-border arrangements evolve. J the App by JustIDT takes a preliminary look on the ramifications.

Background & Overview

The OECD Council approved the 2025 Update to the OECD Model Tax Convention (...

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