OECD publishes Mutual Agreement Procedure Statistics for 2017

Released 10 October 2018

The Organisation for Economic Co-operation and Development (OECD) has published the 2017 Mutual Agreement Procedure (MAP) statistics covering 85 jurisdictions and most MAP cases worldwide.

Improving the effectiveness and timeliness of dispute resolution mechanisms is the aim of Action 14 of the Base Erosion and Profit Shifting (BEPS) Action Plan (see Making Dispute Resolution Mechanisms More Effective, Action 14 - 2015 Final Report). The Action 14 minimum standard requires jurisdictions to seek to resolve MAP cases within an average timeframe of 24 months. To monitor compliance with this, members of the Inclusive Framework on BEPS have committed to report their MAP statistics pursuant to an agreed reporting framework and to publish them on a yearly basis. Highlights of the 2017 statistics now published include:

Compared to 2016, new transfer pricing cases are up by 25% and other cases by 50% meaning that even a 35 % increase in the number of cases closed has not yet prevented the aggregated global inventory from rising.

On average transfer pricing cases continue to take more time than other cases and the averages remain the same as for 2016: approximately 30 months for transfer pricing cases and 17 months for other cases. About 60% of reporting jurisdictions met the 24 months target across all their cases.

More than 80% of MAPs concluded in 2017 resolved the issue for transfer pricing cases and more than 75% for other cases. Approximately 65% of transfer pricing MAP cases closed were resolved with an agreement fully eliminating double taxation and almost 15% of them were granted a unilateral relief.

For more information, see OECD releases 2017 global mutual agreement procedure statistics.

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