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OECD Commentary 2025: Lower risk for remote work — Is it time to rethink your policy?

Tax Alert 2025 No. 57, 17 December 2025

On 19 November 2025, the OECD released an update to the OECD Model Tax Convention and its Commentary. In particular, the Commentary on Article 5 (Permanent Establishment) includes additional guidance on cross-border remote work.

For employers with, or considering, work-from-anywhere policies, the updated Commentary brings much-needed clarity to one of the tax challenges created by employees working abroad.

Access the full content in the PDF attached below.



Previous issues

Valuation for Duty Regulations, take two: CBSA invites feedback on revisions to 2023 proposals

On 3 December 2025, the Canada Border Services Agency (CBSA) announced it is requesting feedback on revisions to proposed amendments to the Valuation for Duty Regulations, which were published in 2023.

Canada announces new measures for steel imports

On 26 November 2025, Prime Minister Mark Carney announced that Canada will reduce tariff rate quotas on certain steel imports and impose a new global tariff on a specific list of steel-derivative products.

2025 budget implementation bill no. 1 introduced in House of Commons

On 18 November 2025, Bill C-15, Budget 2025 Implementation Act, No. 1, received first reading in the House of Commons.

Budget 2025 introduces revised transfer pricing rules

On 4 November 2025, the Minister of Finance and National Revenue, François-Philippe Champagne, tabled the 2025 federal budget, which included substantial draft legislative changes to Canada’s transfer pricing rules in section 247 of the Income Tax Act (the Act).

Federal budget 2025

On 4 November 2025, the Minister of Finance and National Revenue, François-Philippe Champagne, tabled the federal budget 2025. The budget contains tax measures affecting individuals and corporations.

CBSA extends surtax remission for two additional months

On 17 October 2025, the Canada Border Services Agency (CBSA) released a revised version of Customs Notice 25-19, United States Surtax Remission Order (2025) (Customs Notice), which contains new information about the application of the United States Surtax Remission Order (2025).

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