This official document details the 2025 Update to the OECD Model Tax Convention, which implements major changes to international tax treaty standards. Key revisions include adding a new clause to Article 25 regarding dispute resolution coordination with the General Agreement on Trade in Services (GATS), and extensive updates to the Article 5 Commentary to address modern remote working arrangements by establishing a general 50% working time threshold and commercial justification test for home office Permanent Establishments (PE). The update also introduces an optional, lower PE threshold provision for the natural resource extractives sector, clarifies transfer pricing and thin capitalization rules for financial transactions under Article 9 in alignment with BEPS Action 4, signposts dispute mechanisms for Amount B, and expands data usage allowances under exchange of information rules in Article 26.