On 18 November, the OECD Council approved the 2025 Update to the Model Tax Convention. Among the main changes, the Commentary to Article 5 clarifies when remote work may create a permanent establishment, introducing a reference threshold of 50% of working time performed from home, and includes an optional provision for activities related to the exploration and extraction of natural resources. Article 9 has been updated to clarify the treatment of interest expenses in intra-group financial transactions, in light of recent transfer pricing work. A new paragraph 6 has been added to Article 25, concerning the role of the competent authorities within dispute resolution mechanisms, together with further adjustments connected to “Amount B”. Significant amendments have also been introduced in Article 26 on the exchange of information, now clarifying the possibility of using information received even for taxpayers other than those identified in the original request, and regulating access rights for affected taxpayers. These and other developments will be presented during the webinar organised by the SUPSI Centre of Tax & Legal Competence Center, in collaboration with the Ticino Federation of Trustee Associations (FTAF).

Programme and Speakers
Article 5: Personal permanent establishments in the era of remote work
Francesca Amaddeo
Attorney-at-law, Dr. iur., Lecturer-Researcher at the SUPSI Centre of Tax & Legal Competence Center; Of Counsel, Belluzzo International Partners, Switzerland

Article 9: Intra-group financial transactions and interest deductibility
Andrea Brignoli
LL.M., Chartered Accountant, Partner at AM|TAX|LEGAL in Bergamo and Milan

Article 25: New dynamics in international tax dispute resolution
Marco Greggi
Full Professor of Tax Law, University of Ferrara

Article 26: Extended use of exchanged information for other taxpayers
Marco Barassi
Associate Professor of Tax Law, University of Bergamo; Chartered Accountant

Fee
CHF 350.–
CHF 50.– discount for members of partner institutions

Registration
https://bit.ly/webinar-12-05-2026

Registration deadline
Friday, 8 May 2026