OECD releases new BEPS Action 14 MAP peer review results as of June 2025
The OECD's 36 new peer review results under BEPS Action 14, released on 26 June 2025, showcase progress in enhancing treaty-related dispute resolution through the MAP by Inclusive Framework members. The OECD released 36 new peer review results
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OECD publishes dispute resolution peer reviews for 36 jurisdictions
The OECD's peer review reports evaluate the progress of 36 jurisdictions in implementing the BEPS Action 14 minimum standard for resolving tax treaty disputes via the Mutual Agreement Procedure (MAP). The OECD published peer review reports
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UAE issues MAP guidance on double taxation relief
The UAE Ministry of Finance has issued official guidance on the Mutual Agreement Procedure (MAP), outlining how businesses and individuals can seek relief from double taxation under the country’s international tax treaty network. The guidance was
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Germany deposits notifications for MLI entry into force with Czech Republic and Japan
Germany has confirmed completion of its internal procedures for the MLI, enabling its application to tax treaties with the Czech Republic and Japan from 1 January 2026. Germany has deposited its notifications confirming the completion of internal
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Australia: Administrative Review Tribunal rules in favour of Alcoa against ATO in key transfer pricing ruling
This case focused on a major transfer pricing issue, where ATO claimed Alcoa underpriced its alumina sales to Aluminium Bahrain B.S.C. (Alba) from 1993 to 2009, causing a tax shortfall of over AUD 213 million. Australia’s Administrative Review
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Argentina: Senate ratifies BEPS MLI
Argentina's Senate approved the law to ratify the Multilateral Convention on Tax Treaty Measures to Prevent Base Erosion and Profit Shifting (MLI) on 7 May 2025. The Chamber of Deputies approved it in October 2024. Once the internal
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Kenya enforces BEPS Multilateral Instrument (MLI)
The Multilateral Convention to Implement Tax Treaty Measures to Prevent Base Erosion and Profit Shifting (MLI) took effect in Kenya on 1 May 2025. For tax treaties between Kenya and countries where the MLI is already in force, it applies from 1
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OECD releases statement on outcomes of 17th inclusive framework meeting held on 7-10 April
The OECD released a public statement summarizing the key outcomes of the 17th plenary meeting of the OECD/G20 Inclusive Framework on BEPS, which took place from 7-10 April 2025 in Cape Town, South Africa. Domestic tax base erosion and profit
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OECD adds Guernsey to list of qualified Pillar Two jurisdictions
The OECD issued an update on 31 March 2025, in which Guernsey has been added as a jurisdiction with a qualified income inclusion rule (IIR), domestic minimum top-up tax rule (QDMTT), and meeting QDMTT safe harbor standards. This should prevent
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Mongolia joins Multilateral Competent Authority Agreement on Automatic Exchange of Country-by-Country Reports
Mongolia joined the Multilateral Competent Authority Agreement on Automatic Exchange of Country-by-Country Reports (2016) (CbC MCAA) on 6 March 2025. The Country-by-Country Multilateral Competent Authority Agreement (CbC MCAA) is grounded in
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Serbia joins Multilateral Competent Authority Agreement on Automatic Exchange of Country-by-Country Reports
Serbia joined the Multilateral Competent Authority Agreement on Automatic Exchange of Country-by-Country Reports (2016) (CbC MCAA) on 4 March 2025. The Country-by-Country Multilateral Competent Authority Agreement (CbC MCAA) is grounded in
See MoreMongolia: MLI instrument goes into effect on January 2025, announces direct and indirect tax measures
Mongolia has ratified the Multilateral Convention to Implement Tax Treaty Measures to Prevent Base Erosion and Profit Shifting (MLI) on 30 September 2024, which takes effect on 1 January 2025. As of February 2025, the Organisation for Economic
See MoreOECD: Report on Simplified Peer Review of Peru under BEPS Action 14
On 4 March 2025 the OECD issued a stage one simplified peer review report on Peru under BEPS action 14. The report sets out the results of Stage 1 of the simplified peer review of the implementation of the minimum standard on making dispute
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Ukraine: Parliament passes amendments to MLI ratification law
Ukraine’s parliament (Verkhovna Rada) approved Law No. 0293 on 27 February 2025. This law amends Article 1 of the ratification law for the Multilateral Convention to Implement Tax Treaty-Related Measures to Prevent BEPS (MLI). Other key
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OECD revises signatories list for MCAA-CbC as of February 2025
The Organization for Economic Cooperation and Development (OECD) has released an updated list of signatories to the Multilateral Competent Authority Agreement (MCAA) on the Exchange of Country-by-Country (CbC) Reports on 26 February 2025. The
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OECD updates MCAA-CbC signatory list
The Organization for Economic Cooperation and Development (OECD) has released an updated list of signatories to the Multilateral Competent Authority Agreement (MCAA) on the Exchange of Country-by-Country (CbC) Reports on 10 February 2025. The
See MoreKenya ratifies BEPS MLI deposit instrument
Kenya has deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) on 8 January 2025. This follows after Kenya’s National Assembly
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Singapore, New Zealand sign Competent Authority Arrangement on arbitration under BEPS MLI
The Inland Revenue Authority of Singapore has announced the signing of a Competent Authority Arrangement with New Zealand regarding arbitration under the BEPS MLI on 29 November 2024. On 18 and 21 November 2024, the competent authorities of the
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