Outside Publication

OECD Updates Manual on Effective MAP: Practical Tax Takeaways, Bloomberg Law

February 25, 2026

Partners Thomas Linguanti and Drew Cummings co-authored a Bloomberg Law article analyzing the Organisation for Economic Co-operation and Development’s updated Manual on Effective Mutual Agreement Procedures (MAP) and its implications for cross-border tax controversy strategy.

Tom and Drew highlight key themes in the revised guidance, including a renewed emphasis on pragmatic, solution-oriented dispute resolution, greater focus on early-stage analysis and unilateral relief, clarified taxpayer responsibilities, and continued challenges surrounding penalty relief.

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