On October 18, 2021, the OECD published the Stage 2 peer review monitoring reports of BEPS Action 14 (Mutual Agreement Procedure (MAP)) evaluating the progress made by Brazil, Bulgaria, China, Hong Kong (China), Indonesia, Russia and Saudi Arabia in implementing recommendations resulting from their Stage 1 peer review. These reports take into account any developments in the period January 1, 2019 – July 31, 2020 and build on the Mutual Agreement Procedure (MAP) statistics for 2016-2019. Highlights include:

·     The Multilateral Instrument was signed by Bulgaria, China, Hong Kong (China), Indonesia, Russia and Saudi Arabia. It has already been ratified by three of them – Indonesia, Russia and Saudi Arabia – which brings a substantial number of their treaties in line with the Action 14 minimum standard. In addition, there are bilateral negotiations either ongoing or concluded.

·     Bulgaria, China, Hong Kong (China), Indonesia and Saudi Arabia now have a documented bilateral notification/consultation process that they apply in cases where an objection is considered as being not justified by their competent authority.

·     Brazil, Bulgaria, China, Hong Kong (China) and Saudi Arabia have added more personnel to the competent authority function and/or have made organisational improvements with a view to handle MAP cases in a more timely, effective and efficient manner.

·     Hong Kong (China), Russia and Saudi Arabia closed MAP cases within the pursued average time of 24 months, whereas the median time taken by Bulgaria to resolve MAP cases was within this pursued average as well.

·     Russia introduced legislative changes to ensure that MAP agreements can always be implemented notwithstanding domestic time limits, while this was already possible in China and Hong Kong (China).

·     All of the concerned jurisdictions have issued or updated their MAP guidance.

By clicking on the country below you will be forwarded to the stage 2 peer review monitoring report of that respective country.

·     Brazil;

·     Bulgaria;

·     China;

·     Hong Kong (China);

·     Indonesia;

·     Russia; and

·     Saudi Arabia.

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