Latest mutual agreement procedure statistics

Nov 23, 2020

As part of the BEPS Action 14 Minimum Standard and the wider G20/OECD tax certainty agenda to improve the effectiveness and timeliness of tax-related dispute resolution mechanisms, the OECD has released the latest mutual agreement procedure (MAP) statistics covering 105 jurisdictions and almost all MAP cases worldwide.

The BEPS Action 14 Minimum Standard adopted in 2015 by the members of the OECD/G20 Inclusive Framework on BEPS seeks to improve the resolution of tax-related disputes between jurisdictions and includes a peer review mechanism to monitor the compliance of member jurisdictions with this minimum standard.

The 2019 MAP Statistics show the following trends:

  • The number of cases is increasing, driven by a number of factors, including increased globalisation as well as growing confidence in and knowledge of the MAP process.
  • The number of cases closed is also increasing, albeit at a slower pace.
  • The outcomes of the MAPs are generally positive, for example, around 85 percent of the MAPs concluded for transfer pricing cases in 2019 fully resolved the issue (compared to 80 percent in 2018), which reflects an improvement in the collaborative approach taken by competent authorities. Similar to 2018, only 2 percent of the MAP cases were closed without finding a mutual agreement.
  • Cases are still taking a long time to be resolved, on average, MAP cases closed in 2019 lasted for 25 months.