* New cases (cases received on or after 1 January 2016 or 1 January of the year of joining the BEPS Inclusive Framework) are counted using an agreed methodology that uses a common start date. Old cases (cases received prior to 1 January 2016 or 1 January of the year of joining the BEPS Inclusive Framework) are counted based on each reporting jurisdictions’ own methodology without a jurisdiction-by-jurisdiction breakdown and the possibility of reconciliation.
** The closing ratio measures the number of MAP cases closed by each jurisdiction during the reporting year as compared its total MAP caseload. This is calculated by taking the percentage of the number of MAP cases closed during the year over the sum of (i) the number of MAP cases in inventory at the beginning of the year and (ii) half of the number of MAP cases that started during the year. The number of MAP cases started during the reporting year is halved in this ratio as some of the MAP cases started may have started towards the end of the year, making it unreasonable to expect jurisdictions to have closed such cases. This adjustment also explains that the ‘closing ratio’ may be higher than 100% for some jurisdictions.
*** The agreement score measures the number of MAP cases fully resolved in the bilateral phase by the pair of jurisdictions as compared to their total MAP caseload. The score is calculated by comparing (i) the number of MAP cases fully resolved in the bilateral phase with an agreement, either fully eliminating the double taxation or fully resolving the taxation not in accordance with the tax treaty by the pair of jurisdictions with (ii) the sum of the number of MAP cases in inventory at the beginning of the year and half of the number of MAP cases that started during the year. The number of MAP cases started during the reporting year is halved in this computation as some of the MAP cases started may have started towards the end of the year, making it unreasonable to expect jurisdictions to have closed such cases. For instance, a pair of jurisdictions that has 10 cases in their start inventory, 20 cases that start during the year, and that close 10 of them with an agreement, either fully eliminating the double taxation or fully resolving the taxation not in accordance with the tax treaty would have a score of 50 points. The agreement score can be up to 200 points, in very rare circumstances.
**** This figure takes into account the number of APA cases granted and in the end inventory compared to the number of transfer pricing MAP cases closed and in end inventory.
