OECD: BEPS Action 14 MAP peer review results
Progress in making dispute resolution more effective under BEPS Action 14
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June 30, 2025
The Organisation for Economic Cooperation and Development (OECD) has released the latest BEPS Action 14 mutual agreement procedure (MAP) peer review results.
Background
Following the completion of over 80 Stage 1 and Stage 2 peer reviews between 2016 and 2022, the Inclusive Framework on BEPS agreed on a new methodology in December 2022 that includes a simplified peer review process for jurisdictions with no “meaningful MAP experience” and a full peer review process for those with “meaningful MAP experience.”
Latest results
The latest release includes 36 new peer review reports:
- Six new peer review reports under the full peer review process for the following jurisdictions (Cycle 1, Batch 1): Belgium, Canada, Croatia, Estonia, Liechtenstein and United Kingdom
- 30 new peer review reports under the simplified process for the following jurisdictions (Stage 1, Batches 4, 5 and 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
According to the OECD release (June 26, 2025), highlights include:
- The signing and ratification of the Multilateral Instrument (MLI) by all of these jurisdictions brings a large number of tax treaties in line with the Action 14 minimum standard, with bilateral negotiations ongoing or planned for several other treaties.
- Issuance of MAP guidance and publication of MAP profiles by all jurisdictions.
- The establishment of policies and practices that provide access to MAP, enable the effective resolution of MAP cases, and support the implementation of MAP agreements in most eligible cases.
- All jurisdictions have made efforts to improve the resources in their competent authorities and to close their MAP cases within or closer to the 24-month targeted average.