The 2023 Mutual Agreement Procedure (MAP) and Advance Pricing Arrangement (APA) Statistics, the 2023 MAP & APA Awards and the 2024 Consolidated Information on MAP were released during the sixth OECD Tax Certainty Day which took place during the last day of the Forum on Tax Administration (FTA) Plenary Meeting in Athens, Greece and where Commissioners from 53 tax administrations took stock of the tax certainty agenda and discussed ways to further improve dispute prevention and resolution.

The latest MAP Statistics* cover a record 140 jurisdictions and practically all MAP cases worldwide. This was also the first year that jurisdictions filed APA Statistics and that the corresponding APA award for Focus on Dispute Prevention was granted. These statistics form 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 MAP Statistics provide an objective and global frame of reference, as well as a country-specific view, which together allow measurement of progress but also show where further work is needed, while the newly introduced APA Statistics help stakeholders to assess the state of the transfer pricing dispute prevention landscape.

The 2023 MAP & APA Statistics show the following trends:

• For the first time, MAP inventories have decreased, with a 3.8% reduction in end-of-year cases. New transfer pricing MAP cases dropped by 16%, while other cases increased slightly by 2.8%.
• The number of closed MAP cases hit a record, with a 7.4% rise in transfer pricing cases and a 15.8% increase in other cases. This progress reflects the increase of trained staff in many administrations.
• The average resolution time for MAP cases increased to 27.3 months, with transfer pricing cases averaging 32 months and others 23.4 months. Prioritising older cases may account for this increase.
• Approximately 74% of MAP cases in 2023 reached full resolution, consistent with 2022. However, 4% of cases were closed without agreement, potentially due to long-standing unresolved cases being closed.
• A new data point in the 2023 MAP Statistics indicates that 52% of open MAP cases are under two years old, while 24% exceed four years, emphasising the need to address older cases.
• For the first time, 46 jurisdictions with bilateral APA programmes reported their APA statistics, showing an aggregate of over 4000 cases in inventory, an average closure rate of approximately 25% and an average of 36.8 months to agree an APA.

This year's MAP & APA Awards, given in recognition of efforts by competent authorities, saw the following winners: Netherlands and Australia for the shortest time in closing transfer pricing cases and other cases respectively; Canada for the smallest proportion of pre-2016 cases in end inventory; and Netherlands and Norway for the most effective caseload management. The award for the pairs of jurisdictions that dealt the most effectively with their joint caseload went to Canada-France for transfer pricing cases and to Austria-Switzerland for other cases. The award for the most improved jurisdiction went to France, which closed an additional 212 cases with positive outcomes compared to 2022, with increases for both transfer pricing and other cases. Finally, Japan was awarded the first APA award for Focus on Dispute Prevention which aims at shedding light on a jurisdiction’s efforts to prioritise APAs over transfer pricing MAP cases, with 84.7% of its transfer pricing disputes caseload being APAs.

The OECD also released today the 2024 update of the Consolidated Information on Mutual Agreement Procedures summarising published data to give stakeholders a clear overview of the MAP framework in each jurisdiction. 

Further enquiries should be directed to the Communications Office of the OECD Centre for Tax Policy and Administration.

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