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Jurisdiction(s):
United Kingdom
United Kingdom
Key definition
OECD definition What does OECD mean? In legal practice, “OECD” refers to the Organisation for Economic Co‑operation and Development, an intergovernmental body of 38 member countries (including the UK and Ireland) whose economic research, standards and policy recommendations often shape domestic law, treaty practice and compliance. The term is descriptive rather than a defined legal term; however, UK and Irish legislation, regulations and treaties frequently incorporate or refer to OECD instruments. Key touchpoints include: - Tax: the OECD Model Tax Convention, OECD Transfer Pricing Guidelines (used by HMRC and Irish Revenue as interpretative guidance), the BEPS project and Pillar Two/GloBE rules implemented in both jurisdictions. -...
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UK-focused BEPS tracker: OECD updates and UK implementation of Pillar One, Pillar Two and all 15 actions
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LexisNexis Tax expert
Practice notes
DEVELOPMENT :
On 18 November 2025, the OECD Council endorsed updates to the OECD Model Tax Convention on Income and on Capital.
The changes are:
- fresh guidance on the treatment of cross-border ‘home office’ arrangements under tax treaties, giving clarity to employers and staff
- a new optional treaty clause to ensure income from activities linked to natural resource extraction is taxed where it arises, reinforcing source-country taxing rights and supporting resource-rich developing economies
- further refinements to promote consistency in interpreting treaties and to bolster tax certainty
These updates will be reflected in revised condensed and full editions of the OECD Model Tax Convention, scheduled for release in 2026.
This Practice Note sets out the status of the 15 action points in the Organisation for Economic Co-operation and Development (OECD)’s Base Erosion and Profit Shifting (BEPS) project, including any pertinent UK developments.
BEPS describes tax planning tactics used by multinational enterprises to exploit gaps and mismatches in tax Rules, artificially shifting Profits to low- or no-tax locations with little or no economic Activity, resulting in minimal or no overall corporation tax being paid.
The 15 action points are:
- Action 1—Tax challenges arising from...
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Web page updated on 22/05/2026
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