The Manual on Effective Mutual Agreement Procedures (MEMAP) (2026 Edition) 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).
This revised edition 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 discussing practical issues and administering the BEPS Action 14 Minimum Standard peer reviews. 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 MEMAP is designed to assist jurisdictions of all experience levels, offering practical templates for those new to the process and, for the first time, detailed guidance and best practices related to MAP arbitration.
