New OECD Commentary Regarding Home Offices: Recognizing a PE That Should Not Be One?
Journal
Country
International; OECD
Published Date
Issue
Bulletin for International Taxation 2026 (Volume 80), No. 3
Document
In this article, the authors critically examine the 2025 OECD Commentary’s update on home office permanent establishments, assessing whether the newly proposed thresholds provide clarity or instead create legal uncertainty by sidelining the traditional “at the disposal” requirement under article 5 of the OECD Model.