As part of the BEPS Action 14 minimum standard to improve the effectiveness and timeliness of tax-related dispute resolution mechanisms, the OECD released the latest mutual agreement procedure (MAP) statistics covering 118 jurisdictions.

The BEPS Action 14 Minimum Standard adopted in 2015 by 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 2020 MAP Statistics and the 2020 MAP Awards were presented during the third OECD Tax Certainty Day held on 22 November. The 2020 MAP Statistics show the following trends:

• MAP remains concentrated with around 2,500 new cases started in 2020, with the top 25 jurisdictions accounting for 95 percent of cases and the remaining cases involving around 40 other jurisdictions.
• Competent authorities adapted to the COVID-19 pandemic with MAP continuing to be available throughout the pandemic.
• The number of transfer pricing cases has continued to increase, while the number of other cases has slightly decreased compared with 2019.
• There was a slight decrease in cases closed due to COVID-19. Approximately 5 percent fewer MAP cases were closed in 2020 than in 2019.
• Outcomes remain generally positive, around 75 percent of the MAPs concluded in 2020 fully resolved the issue both for transfer pricing and other cases.
• Cases still take a long time to close. On average, MAP cases closed in 2020 took 35 months for transfer pricing cases (31 months in 2019) and approximately 18 months for other cases (22 months in 2019).

In the MAP awards, the award for the most improved jurisdiction, which also highlighted the efforts taken by competent authorities to resolve MAP cases during the COVID-19 crisis, went to Ireland.