OECD releases manual on Multilateral MAPs and APAs

The OECD has published a new Manual on the handling of multilateral mutual agreement procedures and advance pricing arrangements (MoMA). The manual is intended as a guide to multilateral MAP and APA processes from both a legal and procedural perspective and suggests different approaches based on the practices of individual jurisdictions, without imposing a set of binding rules.

The MoMA aims to allow tax administrations to explore whether implementation of these procedures is appropriate considering the circumstances of their own MAP and APA programmes and to consider whether to incorporate the guidance in their domestic guidance on MAP or APA processes. The MoMA also outlines the actions and cooperation expected from taxpayers to allow tax administrations to consider MAP and APA cases multilaterally.