Weekly Roundup with Roustam Vakhitov: Race to Resolve Cross-Border Tax Disputes

Описание: In this episode of Regtalks, Roustam examines the OECD's latest statistics on the mutual agreement procedure (MAP), published on 4 November 2026 at its Tax Certainty Day. The figures reveal a record 2,971 cases closed in 2025, representing a 17.6% increase compared with the previous year.

He explores how MAP helps multinational businesses resolve cross-border tax disputes and eliminate double taxation, particularly following transfer pricing adjustments. The OECD statistics also highlight improvements in resolution times, a stable overall backlog and a reduction in older unresolved cases. However, transfer pricing disputes remain challenging, with the number of open cases continuing to increase.

The episode also examines bilateral advance pricing agreements (APAs), including the 943 agreements granted in 2025 and the lengthy average processing time of more than 40 months.

Roustam discusses the implications for businesses operating across borders, including those in the Netherlands and CIS region, and explains why effective dispute resolution mechanisms are becoming increasingly important amid heightened scrutiny of international transactions and the introduction of the global minimum tax.

As Managing Partner of International Tax Associates B.V. and Associated International Tax Partner at Crowe in Kazakhstan and Azerbaijan, Roustam advises clients across multiple jurisdictions, including the CIS region.

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