The OECD has released the 11th edition of its Model Tax Convention, incorporating updates approved in November 2025 and providing revised guidance on taxing rights, double taxation relief, tax cooperation, and treaty abuse.
The OECD released the 11th edition of the full version of the “OECD Model Tax Convention on Income and on Capital 2025” on 30 September 2026. The publication sets out the changes introduced in the 2025 update to the OECD Model, which were approved on 18 November 2025.
The OECD Model Tax Convention provides a framework for allocating taxing rights between source and residence states and reducing the risk of double taxation. It includes standardised relief methods, including exemption and credit mechanisms, to support cross-border trade, services, and investment. The updated publication also covers measures to strengthen international tax cooperation and address tax evasion and avoidance.
Key functions of the OECD Model Tax Convention include:
Reducing double taxation: Establishes rules for allocating taxing rights between source and residence states and provides exemption or credit methods to relieve double taxation on cross-border income.
Strengthening tax cooperation: Supports administrative cooperation through the exchange of information and assistance in the collection of taxes, while incorporating provisions to address tax avoidance and treaty abuse.
Promoting global consistency: Serves as a widely used reference for negotiating and updating bilateral tax treaties among OECD and non-OECD economies and contributes to the development of international tax standards.
