2 February 2026 the OECD has released a new 2026 version of the Manual on Effective Mutual Agreement Procedures (MEMAP). The Manual supports the broader focus of the BEPS Inclusive Framework and Forum on Tax Administration (FTA) to improve international tax dispute resolution as part of the tax certainty agenda. Building on the 2007 edition, it provides non-binding, comprehensive practical guidance to competent authorities and taxpayers on the effective conduct of the Mutual Agreement Procedure (MAP). It features 59 best practices targeted at both competent authorities and taxpayers that were developed directly by competent authorities in the FTA MAP Forum, based on input from all stakeholders and grounded in over a decade of experience. Beyond detailed procedural guidance, the Manual addresses organisational considerations, such as the ideal staffing of a competent authority function and the solution-oriented mindset required to handle cases effectively. It also outlines steps that jurisdictions can take to proactively prevent disputes. The Manual is designed to assist ... Read more

Following an Austrian tax audit of related-party transactions between an Austrian GmbH and a Liechtenstein AG holding intangible assets, Austria's Federal Ministry of Finance submitted an information request under the Austria-Liechtenstein DTA. The Liechtenstein Constitutional Court ruled in favour of the tax authority in August 2021, upholding the validity of the request concerning intra-group IP, data, and service billing arrangements ... Read more

A Belgian competent authority requested transfer pricing documentation from Luxembourg's tax administration regarding intra-group service payments made to Lux Service SA. When the Luxembourg tax administration issued an information injunction, Lux Service SA sought annulment before the Administrative Tribunal. In December 2020, the tribunal dismissed the appeal, finding the injunction was sufficiently reasoned based on Belgium's request, and ruled in favour of the tax authority ... Read more

A German company sought mutual agreement and arbitration proceedings under the EU Arbitration Convention to eliminate double taxation arising from a transfer pricing adjustment between Germany and Spain. The German tax authority denied the request on grounds of a highly punishable tax violation by the taxpayer. The Bundesfinanzhof upheld the denial in 2019, confirming that competent authorities retain full discretion to refuse MAP proceedings in such circumstances ... Read more