Recognising that the actions to counter Base Erosion and Profit Shifting (“BEPS”) must be complemented with actions that ensure certainty for taxpayers, BEPS Action 14 calls for effective dispute resolution mechanisms. The report on Action 14: Making Dispute Resolution Mechanisms More Effective1 (OECD, 2015) includes a minimum standard that all members of the Inclusive Framework on BEPS (“Inclusive Framework Members”) have committed to implement, which ensures that these Inclusive Framework Members resolve treaty-related disputes in a timely, effective and efficient manner, particularly through the Mutual Agreement Procedure (“MAP”).

Pursuant to implementing the Action 14 minimum standard, Inclusive Framework Members have now published an unprecedented amount of information on their MAP programmes. This includes: (i) rules, guidelines and procedures to access and use MAP, made available to taxpayers usually through the website of their ministry of finance or tax administration ; (ii) a country MAP profile pursuant to an agreed template on a shared public platform available on the OECD website, ; (iii) MAP statistics, pursuant to an agreed reporting framework2, available on the OECD website; and (iv) peer review reports under the Action 14 minimum standard that provide information on how the Inclusive Framework Member has implemented the Action 14 minimum standard , also available on the OECD website. However, previously this information was only available in different places, so taxpayers and MAP competent authorities had to seek out this information for each Inclusive Framework Member separately.

To make this information more accessible to all stakeholders, the FTA MAP Forum agreed in December 2022 to summarise and consolidate published information concerning MAP for all Inclusive Framework Members in a single publication, titled Consolidated Information on Mutual Agreement Procedures (“Report”). The objective behind the Report is to give a concise picture of each Inclusive Framework Member’s MAP programme, to further highlight the ongoing efforts in the FTA MAP Forum to make the MAP more timely, effective and efficient.

This Report sets out for each Inclusive Framework Member: (i) recent developments concerning MAP; (ii) a brief overview of its MAP programme, including its tax treaty network, the organisation of its competent authority, and links to its MAP guidance and MAP profile; and (iii) a summary of its MAP Statistics, with the exception of jurisdictions that do not have tax treaties that are in force containing any provisions on the allocation of taxing rights.3 Where information in any category has not been provided by the jurisdiction concerned, this is noted in the relevant section. The overview of each jurisdiction’s MAP Statistics contained in this Report presents the data that was submitted by that jurisdiction for publication on the OECD website each year and does not take into account any adjustments made in the course of the peer reviews under Action 14 or otherwise following publication of that year’s MAP Statistics