Ramiro Morales

Introduction The 2025 Update to the OECD Model Tax Convention (MTC) reflects a series of targeted doctrinal clarifications rather than a wholesale structural revision. Taken together, the changes respond to longstanding interpretive uncertainties across three thematic pillars: the scope of permanent establishment in modern working arrangements and extractive industries; the interface between Article 9 transfer pricing principles and domestic interest limitation rules; and the procedural...

Introduction Double tax treaties (DTTs) also referred to as double taxation avoidance agreements or conventions constitute the backbone of the international tax architecture. Concluded bilaterally between sovereign states, their primary function is to eliminate or mitigate the risk that the same income is subjected to taxation in two or more jurisdictions simultaneously. By allocating taxing rights between a source state and a residence state, treaties provide legal certainty, reduce...

The last quarter of 2025 and the beginning of 2026 saw several significant developments in bilateral double taxation treaties (DTTs). These developments include amendments through protocols, the entry into force of new treaties, and the modernization of existing agreements to reflect post-BEPS standards and evolving cross-border employment patterns. The following sections outline the most relevant treaties and emphasize the principal changes introduced. Netherlands – Germany: Protocol...