Newsalert | Tax 21/11/2025

On 18 November 2025, the OECD Council approved the contents of the 2025 Update to the OECD Model Tax Convention on Income and on Capital, introducing significant amendments to the OECD Model Tax Convention, its Commentary and the positions of both member and non-member economies. 

In the latest newsalert, Chiomenti Professionals provided an overview of the most relevant amendments introduced by the 2025 Update in the areas of transfer pricing and mutual agreement procedures, with a focus on the revisions to the Commentary on Article 9 and related changes to the Commentary on Article 7, as well as the amendments to Article 25 and its Commentary.