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ARTICLE · 25 FEBRUARY 2026

MEMAP – Navigating An Efficient Path To Double Taxation Relief

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On 2 February 2026 the OECD published its Manual on Effective Mutual Agreement Procedures (2026 Edition) (the “MEMAP”). The MEMAP is a practical and aspirational ‘best practice’ guide for competent authorities and taxpayers on mutual agreement procedures (“MEMAP”) to resolve double taxation.

IrelandTax
Mark O'Sullivan
Mark O'Sullivan
Anna Crowley
Anna Crowley
Eimear Meally
Eimear Meally
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On 2 February 2026 the OECD published its Manual on Effective Mutual Agreement Procedures (2026 Edition) (the “MEMAP”).  The MEMAP is a practical and aspirational ‘best practice’ guide for competent authorities and taxpayers on mutual agreement procedures (“MEMAP”) to resolve double taxation.

The MEMAP (2026 Edition) has been released nearly 20 years after the original MEMAP (2007 Edition).  Reflecting on the evolution of MAP since the 2007 Edition, the MAP landscape has changed significantly in Ireland and internationally.  OECD statistics show that the global MAP inventory has more than doubled in that period (from over 2,500 MAPs in 2007 to over 6,000 MAPs based on the latest 2024 statistics).  Not only has the volume of MAP cases grown, the issues that are presented in MAP cases have become increasingly complex and frequently have a multi-lateral dimension. Given the growing demand for tax certainty, the MEMAP provides a timely roadmap for making MAP more efficient and

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