OECD PE developmentsOECD releases a public consultation to update the Commentary on Article 5 of the OECD Model Tax ConventionOn 16 November 2023, the Organisation for Economic Co-operation and Development (OECD) released a public consultation on proposed changes to the Commentary on Article 5 of the OECD Model Tax Convention and its application to extractible natural resources.The consultation document comprises an alternate provision for both onshore and offshore activities related to the exploration and exploitation of extractible natural resources such as oil, gas, and minerals, together with related commentary. As per the proposed provision, relevant activities in the source state...