OECD Releases Information and Statistics on Mutual Agreement Procedures

On 14 November 2023 the OECD released the 2022 Mutual Agreement Procedures (MAP) Statistics, covering 133 jurisdictions worldwide. The release of these statistics each year is part of the actions to improve dispute prevention and resolution in line with the action plan on base erosion and profit shifting (BEPS). Action 14 aims to improve the timeliness and effectiveness of tax dispute resolution mechanisms and the operation of MAP procedures can be monitored by reference to these statistics. The minimum standard under action 14 assesses the legal and administrative framework in each jurisdiction in relation to prevention of disputes; the availability and access to MAP; resolution of MAP cases; and the implementation of MAP agreements.

The statistics indicate how much progress has been made in improving the MAP procedures and also indicate the areas where further efforts are needed. The 2022 MAP Statistics show that the outcomes of MAPs were generally positive. Around 73% of the cases concluded in the year fully resolved the relevant issue, both for transfer pricing cases and in other cases. In 2022 around 2% of MAP cases were closed with no agreement, which was a similar proportion to the previous year.

The average time required to close MAP cases in 2022 was 25.3 months, a slight improvement on the time of 26 months required in 2021. The time required to complete transfer pricing cases in 2022 was 29 months, down from 32.3 months in the previous year. These results are closer to the target time of 24 months. They have been achieved even though taxpayers are requesting MAPs more than in previous years. The faster time to close cases reflects the greater resources available to competent authorities and improved case management. This shows that countries are putting significant investments into their competent authority functions.

The Netherlands and Norway received “MAP awards” for requiring the shortest time on average to close transfer pricing and other MAP cases respectively. Luxembourg and Norway received awards for the most effective caseload management. The Netherlands was recognised as the most improved jurisdiction, closing 102 cases more with a positive outcome compared to the results for the previous year.

The OECD has also released consolidated information on mutual agreement procedures, providing an overview of the published MAP information in each member jurisdiction of the OECD/G20 Inclusive Framework on BEPS in a clear and simple manner. This consolidated information will be released annually with the MAP Statistics for the year.


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