In February 2026, the OECD released an updated Manual on Effective Mutual Agreement Procedures (MAP), refining guidance on handling tax treaty disputes. While not legally binding, the Manual promotes faster, more practical and solution-focused case management, aiming to reduce resolution times that currently exceed the 24-month target. It stresses confidentiality, early case assessment, possible unilateral relief, clearer taxpayer responsibilities, and better coordination across years. Although challenges remain—particularly regarding penalties and multilateral cases—the update seeks to standardize practice and ease growing pressure on competent authorities dealing with cross-border tax disputes.
To access the Manual, click here.
OECD released the long-awaited update to its Manual on Effective Mutual Agreement Procedures, offering practical guidance on how taxpayers and tax authorities can better navigate the mutual agreement procedure (MAP) used to resolve double taxation disputes under tax treaties.
The updated manual does not change existing treaty rules, but modernizes the 2007 guidance by explaining how MAP works in practice today, highlighting best practices, common challenges, and emerging issues. Developed since 2023 with input from a focus group of 17 jurisdictions and extensive consultation with tax authorities and businesses, the new manual aims to make cross-border dispute resolution more predictable, transparent, and effective for all parties involved.
To access the MAP Guidance, click here.
On October 23, 2025 Belgium’s tax authority published online the Circular 2025/C/68, guiding on the applicability of OECD’s 15% global minimum tax for large multinational groups. The guidance, among others, explains the administration aspects of the income inclusion rule, qualified domestic top-up tax, and undertaxed profits rule. Also, it clarifies the treatment of R&D tax credits and controlled foreign corporations.
To access the Circular, click here.