Following the progress achieved in the area of Advance Pricing Arrangements (APAs) through the Bilateral Advance Pricing Arrangement Manual (BAPAM), the OECD published the Advance Pricing Arrangement (APA) Statistics Reporting Framework in 2023. This framework showcases Inclusive Framework (IF) members’ efforts to increase tax certainty through dispute prevention in addition to all the work that has been done on the dispute resolution side. Under the new framework, all BEPS Inclusive Framework member jurisdictions with bilateral or multilateral APA programs, or that can enter such agreements under their domestic laws or tax treaties, commit to reporting APA Statistics based on agreed criteria, while retaining the flexibility to use their own reporting cycles and definitions for “Start Date” and “End Date” when calculating the average time to close APA cases. Reporting jurisdictions are not required to align their APA Statistics with those of their treaty partners. The 2023 APA Statistics are the first set published under this framework and include data from all relevant IF members that joined the Inclusive Framework prior to 2024.
2023 Advance Pricing Arrangement Statistics
In line with the OECD/G20 tax certainty agenda, which promotes dispute prevention, APA Statistics are a new metric designed to provide a clearer, more accurate view of a jurisdiction’s dispute prevention and resolution efforts, enhancing transparency in this area. When read alongside MAP Statistics, APA Statistics give stakeholders a more complete picture of a jurisdiction’s approach to preventing and resolving transfer pricing disputes.
About
At a glance
| 2023 Start inventory | Cases started | Cases closed | 2023 End inventory | Average time taken in months to grant APAs during the reporting period | |||
|---|---|---|---|---|---|---|---|
| Granted | Rejected | Other reason | |||||
| APA cases | 3919 | 1136 | 860 | 15 | 100 | 4080 | 36.79 |
Breakdown per reporting jurisdiction
Only IF members that already have a bilateral/multilateral APA programme or can enter into such APAs under domestic law and/or tax treaties should report their annual APA statistics.
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Further information
- Bilateral Advance Pricing Arrangement Manual (BAPAM)
- Manual on the Handling of Multilateral Mutual Agreement Procedures and Advance Pricing Arrangements (MoMA)
- Learn more about OECD work on tax certainty, dispute resolution and ICAP
- Contact us by e-mail: ctp.contact@oecd.org
- Follow us on social media: @OECDtax (X/Twitter) & OECD Tax (LinkedIn)
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