[World Tax News] OECD Releases Revised Manual on Effective Mutual Agreement Procedures and More

Editorial Team – [2026] 183 taxmann.com 199 (Article)

World Tax News provides a weekly snippet of tax news from around the globe. Here is a glimpse of the tax happening in the world this week:

1. OECD Releases Revised Manual on Effective Mutual Agreement Procedures 2026 Edition

The OECD has announced the release of the Manual on Effective Mutual Agreement Procedures (MEMAP) 2026 Edition, updated under the Inclusive Framework on BEPS. The revised manual aims to improve tax certainty by supporting tax administrations and taxpayers in resolving cross-border tax treaty disputes efficiently, effectively, and in a timely manner.

The 2026 MEMAP serves as a practical roadmap for navigating the Mutual Agreement Procedure (MAP) and includes structured guidance, templates and best practices to promote consistent and effective international tax dispute resolution. While it builds on the 2007 edition, the revised version adopts a new structure shaped by the real-world experience of competent authorities. It contains 59 aspirational best practices, drawing on inputs from both tax administrations and business, as well as insights from more than a decade of BEPS Action 14 peer reviews and discussions on MAP cases.

The manual provides practical guidance across the full MAP lifecycle, structured around four key areas:

(a) Dispute prevention and competent authority organisation, including pre-MAP consultations and measures to prevent disputes early;

(b) Access to MAP and unilateral relief, covering eligibility, the structure of MAP requests, and circumstances where unilateral relief may resolve issues without bilateral negotiation;

(c) Bilateral discussions and MAP arbitration, including advice on position papers, meetings and, for the first time, detailed guidance and best practices on MAP arbitration; and

(d) Capacity building and templates, including support for low-capacity jurisdictions and practical tools such as templates for MAP requests and position papers.

Source – Announcement

2. Canada Issues Updated Guidance on Global Minimum Tax Filing Requirements

The Canadian Government has released updated guidance (dated 30 January 2026) to help taxpayers prepare for Global Minimum Tax filings. The guidance outlines the required filing schemas, due dates, and information to be collected in advance, including for the GloBE Information Return (GIR), the Global Minimum Tax Return, and the GIR Notification.

The filing deadline is 18 months after the last day of the fiscal year in which an entity of a qualifying MNE group is first subject to the rules, and 15 months after the fiscal year-end in all other cases. For fiscal years beginning on or after 31 December 2023 and ending on or before 31 December 2024, the due date for the prescribed returns or notification is 30 June 2026.

All filings must be submitted electronically through an API. The GIR must be filed using an XML schema, while the Global Minimum Tax Return and the GIR Notification must be filed using a JSON schema.

Source – Official Website

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