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
See More
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
See More
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
See More
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
See More
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
See More
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
See More
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
See More
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
See More
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
See More
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,
See More
Israel releases Guidance on MAP and APA procedures
On 17 August 2023, the Israel Tax Authority (ITA) released Tax Circular No. 1/2023, which provides guidance for mutual agreement procedure (MAP), and bilateral advance pricing agreement (APA) requests. The new circular replaces the guidance of
See More
Georgia adopts rules on Mutual Agreement Procedures (MAP)
The Ministry of Finance of Georgia recently published Decree No. 258 of July 2023, which approves the rules for the Mutual Agreement Procedures (MAP) under the Tax Treaties of Georgia or the provisions of the BEPS MLI. The rules encompass various
See More
Nigeria: FIRS releases new guidelines on mutual agreement procedures
On 23 May 2023, the Federal Inland Revenue Service (FIRS) of Nigeria has released Information Circular No. 2023/04 which includes new Guidelines on Mutual Agreement Procedure (MAP). The purpose of the guidelines is to provide guidance on how to
See More
Sri Lanka: IRD publishes MAP guidelines
On 8 May 2023, the Sri Lanka Inland Revenue Department (IRD) has published Mutual Agreement Procedure (MAP) guidelines. The guidelines provide several key aspects related to Mutual Agreement Procedure (MAP) requests in Sri Lanka. The guidelines
See More
Chile: Tax authority clarifies time limits for MAP requests
On 19 April 2023, Circular No. 19 was released by the Chilean tax authority. This circular modifies Circular No. 13, which was published on 18 March 2022, which provides guidance on the Mutual Agreement Procedures (MAP) under Chile’s tax treaties.
See More
Luxembourg: Government submits draft bill on transfer pricing and general tax procedures
On 28 March 2023, the Luxembourg government submitted Bill No. 8186 to the Parliament. The bill includes changes in advance pricing arrangement (APA), mutual agreement procedure (MAP), compliance with transfer pricing documentation requirements, and
See MoreChile launches public consultation on MAP
The Internal Revenue Service (SII) of Chile has launched a public consultation on a draft circular that aims to clarify the 3-year deadline for submitting a mutual agreement procedure (MAP) request. The SII is accepting feedback from the public
See More
Malaysia: IRBM issues FAQs to clarify MAP guidelines
On 1 February 2023, the Inland Revenue Board of Malaysia (IRBM) has issued a list of frequently asked questions (FAQs) on the mutual agreement procedure (MAP) to provide further clarification to the 2017 MAP guidelines. In relation to the
See More