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By Alessia ECCHER and Eduardo MEDINA, EY Luxembourg *
On 2 February 2026, the Organization for Economic Co-operation and Development (“OECD”) published an updated edition of the Manual on Effective Mutual Agreement Procedures (“2026 MEMAP”), providing revised guidance on the conduct of Mutual Agreement Procedures (“MAPs”). The update represents an important step in the continued effort to further improve international tax dispute resolution.
For Luxembourg—a jurisdiction where cross-border structures form an integral part of the economic and tax framework and rely extensively on treaty-based dispute resolution—the 2026 MEMAP provides a relevant reference to assess existing practice. It also has implications for taxpayers, and for Luxembourg’s...
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