The OECD has released updated guidance by the Inclusive Framework on BEPS, aimed at improving tax certainty by helping tax administrations and taxpayers resolve cross-border tax treaty disputes in an efficient, effective and timely manner.
The Manual on Effective Mutual Agreement Procedures (MEMAP): 2026 Edition serves as a roadmap for navigating the Mutual Agreement Procedures (MAP) and includes practical guidance, best practices and templates to support consistent and effective international tax dispute resolution.
While building on the foundation of the 2007 edition, the revised MEMAP introduces a new structure informed by real-world experience of competent authorities.
The Manual features 59 aspirational best practices drawing on input from both tax administrations and business, as well as on more than a decade of insights from the BEPS Action 14 peer reviews and practical discussions on MAP cases.