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How OECD Tax Update Tackles Mobile Workforce Complexity

December 18, 2025

United States
United States
United States
Law360

In this article published by Law360, Eversheds Sutherland attorneys Megan Hall, Caroline Setliffe, Brian Tschosik, Megan Long and Reid Tomasello analyze the 2025 Update to the OECD Model Tax Convention. The update introduces significant revisions to the commentary on permanent establishment, transfer pricing, and exchange of information, providing new guidance for multinational companies managing mobile workforces and cross-border tax compliance.

The materials on the Eversheds Sutherland website are for general information purposes only and do not constitute legal advice. While reasonable care is taken to ensure accuracy, the materials may not reflect the most current legal developments. Eversheds Sutherland disclaims liability for actions taken based on the materials. Always consult a qualified lawyer for specific legal matters. To view the full disclaimer, see our Terms and Conditions or Disclaimer section in the footer.

Key contacts

meganhall@eversheds-sutherland.com

Megan K. Hall

Partner

Washington, DC, United States

carolinesetliffe@eversheds-sutherland.com

Caroline C. Setliffe

Partner

Washington, DC, United States

briantschosik@eversheds-sutherland.com

Brian Tschosik

Partner

Washington, DC, United States

reidtomasello@eversheds-sutherland.com

Reid Tomasello

Senior Associate

Washington, DC, United States

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