Are Micro Home Office PEs Tackled under the 2025 Update to the Commentary on the OECD Model?

In this note, the author critically examines the 2025 Update to the OECD Model and its related Commentary on home office PEs, assessing whether the new provisions offer a more effective approach to addressing the risk of proliferating micro home office PEs compared to the Commentary on the OECD Model (2017). While the additional criteria may help limit the creation of micro-PEs so that employees trigger home office PEs only in exceptional cases, practical challenges may still arise.