KPMG article: Updated OECD manual on mutual agreement procedures (MAPs)
February 2026 manual provides clear and comprehensive end-to-end guidance on MAP and useful template documents.
The Organisation for Economic Cooperation and Development (OECD) on February 2, 2026, published an updated version of the Manual on Effective Mutual Agreement Procedures (MEMAP).
The MEMAP is intended to serve “as a comprehensive guide for navigating the Mutual Agreement Procedure,” and running to over 150 pages, the manual is certainly comprehensive. But the big question for taxpayers is this: Will this guidance make MAP more effective and efficient?
Read an April 2026 article* explaining that, despite the MEMAP’s nonbinding status, it provides clear and comprehensive end-to-end guidance on MAP and useful template documents, which can help taxpayers and tax administrations, particularly in low-capacity jurisdictions, navigate MAP successfully. Adoption is likely to vary by jurisdiction, but the best practices were approved by over 140 BEPS-inclusive framework jurisdictions, making it a significant step toward addressing the main issues the business community has highlighted as barriers to effective MAP.
* This article originally appeared in Tax Notes International (April 13, 2026) and is provided with permission.