OECD releases revised version of the Manual on Effective Mutual Agreement Procedures (2026 edition)

Contacts

camilla cominelli Module
Camilla Cominelli

Senior Associate
Italy

I am a tax adviser working in the Italian tax department. I specialise in transfer pricing, providing consultancy and assistance to multinational clients in relation to international tax issues.

carolina mason Module
Carolina Mason

Associate
Italy

I'm a tax advisor working in the Italian tax department with a focus on international taxation matters, with specific skills in transfer pricing.

In February 2026, the OECD published the updated Manual on Effective Mutual Agreement Procedures (MEMAP), representing the first comprehensive update since the 2007 edition. This modernization, developed through a revision project initiated by the Forum on Tax Administration (FTA) MAP Forum in 2023, integrates over a decade of insights derived from the Action 14 BEPS peer reviews.

The manual provides updated practical guidance reflecting current practice and experience, identifies key issues arising at each process stage, and outlines good practices developed by competent authorities and businesses alike, whilst complementing rather than replacing the OECD Model Tax Convention and Transfer Pricing Guidelines.

Please read the alert written by our professionals, Camilla Cominelli and Carolina Mason, at the following link.
 

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