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 assessing the implementation of dispute resolution standards under BEPS Action 14 for 36 jurisdictions on 26 June 2025.

These reports reflect ongoing efforts by members of the Inclusive Framework on BEPS to meet the Action 14 minimum standard, which aims to improve the resolution of treaty-related disputes through the Mutual Agreement Procedure (MAP).

The reviews were conducted under a new Assessment Methodology, which includes:

  • A simplified peer review process for jurisdictions with limited MAP experience, helping them build more robust programmes in anticipation of future case volumes.
  • A full peer review process for jurisdictions with meaningful MAP experience, ensuring continued compliance and monitoring.

Reports Released:

  • Full peer review (Cycle 1, Batch 1): Belgium, Canada, Croatia, Estonia, Liechtenstein, and the United Kingdom. These six jurisdictions underwent their third round of reviews.
  • Simplified peer review (Stage 1, Batches 4–6): Andorra, Armenia, Azerbaijan, Bahamas, Bermuda, Bosnia and Herzegovina, British Virgin Islands, Brunei Darussalam, Congo, Côte d’Ivoire, Curaçao, Democratic Republic of the Congo, Faroe Islands, Gabon, Georgia, Isle of Man, Jersey, Kenya, Macau (China), Maldives, Mauritania, Monaco, Mongolia, Panama, Papua New Guinea, Paraguay, San Marino, Sierra Leone, Togo, and Uruguay.

Key Findings from Full Peer Reviews:

  • All six jurisdictions have signed and ratified the Multilateral Instrument (MLI) to align their tax treaties with the Action 14 standard.
  • MAP guidance and profiles have been published in each jurisdiction.
  • Effective MAP access, timely resolution, and implementation of outcomes are in place in most cases.
  • Jurisdictions have strengthened their MAP resources and improved case closure timelines, moving closer to the 24-month target.

Key Outcomes from Simplified Peer Reviews:

  • Most jurisdictions reviewed have taken, or committed to take, steps to develop a functional MAP framework.
  • Supporting evidence includes MLI-based treaty modifications, MAP guidance or plans to issue it, improved access policies, and competent authorities aligned with Action 14 expectations.