On October 20, 2016 the OECD launched the global review of Mutual Agreement Procedures (MAP) programmes by releasing key documents, approved by the Inclusive Framework on BEPS, that will form the basis of the Mutual Agreement Procedure peer review and monitoring process under Action 14 of the BEPS Action Plan. (For further information we refer to our article of October 20, 2016).


On October 31, 2016 the OECD subsequently released an Assessment Schedule for Stage 1 Peer Reviews. The peer reviews are being conducted in batches. (Click here to be forwarded to the Assessment Schedule for Stage 1 Peer Reviews as released by the OECD on October 31, 2016.)


A seventh batch of peer reviews, which is supposed to commence in December 2018. During this seventh batch peer reviews of the MAP programmes of:

·   Brazil;

·   Bulgaria;

·   People’s Republic of China;

·   Hong Kong;

·   Indonesia;

·   Papua New Guinea;

·   Russian Federation; and

·   Saudi Arabia will be conducted.


In preparation for this seventh batch of reviews and in recognition of the fact that taxpayers are the main users of the MAP, the FTA MAP Forum invites taxpayers to provide input on specific areas. In this respect the OECD has released a Questionnaire for taxpayers concerning MAP experiences regarding a specific country that is being assessed. The OECD is looking for input on each of the jurisdictions that are part of the seventh batch. Input has to be provided for each separate country via a so-called taxpayer input questionnaire. The questionnaire comes in the form of a downloadable Word-document.


The questionnaire contains three areas for which the OECD is asking input:

- Access to MAP

- Clarity and Availability of MAP Guidance

- Implementation of MAP Agreements


Completed questionnaires should be sent in Word format to This email address is being protected from spambots. You need JavaScript enabled to view it. at the latest by December 13, 2018.


Click here to download the taxpayer input questionnaire from the OECD website.



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