Worldwide: Tax Treaties

Malta and Bulgaria have amended their double taxation treaty to align the Mutual Agreement Procedure with OECD standards, introducing a justification requirement that was conspicuously absent from the original text. While this change brings the treaty into conformity with international practice, the absence of mandatory arbitration provisions means taxpayers still lack a binding dispute resolution mechanism if competent authorities reach an impasse.

For international businesses with UAE operations, the Cyprus UAE holding structure has moved from a niche advisory conversation to a mainstream planning consideration.

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.