Australia: ATO revises guidance on mutual agreement procedure requests
The Australian Taxation Office (ATO) has updated its guidance on 19 June 2026 regarding requests for mutual agreement procedures (MAPs) to resolve cross-border tax disputes arising from alleged violations of double taxation agreements (DTAs). This
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Peru: SUNAT issues MAP guidance 2.0 (2026), updates tax treaty dispute framework
The Peru tax authority (SUNAT) has introduced Mutual Agreement Procedure Guidance Version 2.0 (2026) to replace the previous Mutual Agreement Procedure Guidance Version 1.0 (2023). The 2026 version of the Mutual Agreement Procedure (MAP) Guide
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Romania consults new mutual agreement procedure (MAP) rules
Romania’s National Agency for Fiscal Administration (ANAF) initiated a public consultation, on 21 April 2026, on a draft order establishing the procedure for conducting the mutual agreement procedure (MAP), following amendments introduced to the
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France clarifies MAP access rules, APA roll-back conditions in transfer pricing guidance
The French tax authority issued updated guidance on Mutual Agreement Procedures (MAP) and Advance Pricing Agreements (APA) on 15 April 2026, following a public consultation launched on 15 January 2025. The revisions provide clarification on MAP
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Russia: MoF updates guidance on mutual agreement procedure requests
The Russian Ministry of Finance (MoF) published updated guidance on requesting assistance under the Mutual Agreement Procedure (MAP), setting out detailed rules for taxpayers seeking relief from double taxation under applicable double taxation
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OECD introduces manual on mutual agreement procedures via technical webinar
The OECD hosted a technical webinar on the revised Manual on Effective Mutual Agreement Procedures (MEMAP) on 10 February 2026, in support of the broader focus of the BEPS Inclusive Framework and the Forum on Tax Administration (FTA) on improving
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Colombia: DIAN highlights 2025 transfer pricing adjustment requirements
Colombia’s tax authority (DIAN) has issued a notification, on 6 February 2026, for large taxpayers subject to the transfer pricing regime to make any required transfer pricing adjustments when filing their 2025 fiscal year income tax return. As
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OECD updates manual on effective mutual agreement procedures
The OECD has released updated guidance by the Inclusive Framework on BEPS on 2 February 2026, aimed at improving tax certainty by helping tax administrations and taxpayers resolve cross-border tax treaty disputes in an efficient, effective and
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US: IRS releases US–Spain competent authority agreement on arbitration
The US Internal Revenue Service (IRS) has released Internal Revenue Bulletin No. 2026-6 on 2 February 2026. The bulletin includes Announcement 2026-3, which sets out the Competent Authority Arrangement agreed between the US and Spain to implement
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OECD reports increase in MAP and APA caseloads in 2024 data published on Tax Certainty Day 2025
The OECD has released new tax dispute statistics, highlighting generally positive results despite ongoing challenges on 31 October 2025. Tax certainty: OECD releases new statistics on tax disputes, showing positive outcomes but with challenges
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US: Court of Appeals determines tax authorities cannot reallocate income beyond a taxpayer’s legal entitlementÂ
The IRS sought to reallocate an additional USD 23.7 million in royalties to 3M under the arm’s-length standard, despite the company’s Brazilian subsidiary being legally limited to paying only USD 5.1 million. The US Court of Appeals for the
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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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Malta issues updated guidelines for mutual agreement procedure
Malta's Commissioner for Revenue has issued the updated guidelines on  Mutual Agreement Procedure (MAP) Guidelines on 11 March 2025. These guidelines explain how the MAP functions, allowing Malta’s Competent Authority to collaborate with
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Chile revises procedures for transfer pricing adjustment requests
Chile's Internal Revenue Service (SII) has published Resolution No. 6 of 9 January 2025, which updates procedures for requesting transfer pricing adjustments after adjustments by foreign tax authorities. It updates and replaces Resolution No. 67
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US, Norway Competent Authority Arrangement (CAA) enters into force
The US Internal Revenue Service (IRS) has issued Announcement 2024-42 on 9 December 2024 in which it notified taxpayers the US and Norway has entered a competent authority arrangement (CAA) in accordance to the paragraph 2 of Article 27 (mutual
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UK considers changes to transfer pricing, advance pricing rules in Autumn Budget 2024
UK’s Chancellor of the Exchequer Rachel Reeves, in her Autumn Budget 2025 announcement on 30 October 2024, said her government is considering modernising the country’s transfer pricing rules and the advance pricing agreement system. Reeves
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Bahamas issues MAP guidance with Japan
The Bahamas Ministry of Finance has released guidance on Mutual Agreement Procedures (MAP) with Japan as per the tax information exchange agreement between the two nations. The guidance details the scope of MAP, eligibility for requesting MAP,
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US: IRS releases 2025 HSA inflation-adjusted amounts
The US Internal Revenue Service (IRS) published on Thursday, 9 May, 2024, the Rev. Proc. 2024-25, in which it detailed the inflation-adjusted limits for Health Savings Accounts (HSAs) and High Deductible Health Plans (HDHPs) for the 2025 calendar
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