This session examines the OECD’s 2025 update to the Commentary on Article 5 and what it means for permanent establishment (PE) risk in a world of cross-border remote work.

We’ll analyze key clarifications and remaining uncertainties on PE (including profit allocation), anticipated approaches by major jurisdictions, and leading practice responses by multinational groups, including interactions with personal income tax.

We’ll also discuss potential future OECD initiatives and their impact on global operating models. You’ll gain concrete insights to recalibrate risk assessments, refine governance, and align remote work policies and guardrails with international corporate tax strategy while supporting flexible working arrangements.