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EU: Statistics of APAs and MAPs for 2018

EU: Statistics of APAs and MAPs for 2018

The European Commission in July 2019 published statistics on pending advance pricing agreements (APAs) and mutual agreement procedures (MAPs) for 2018.


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Read the EC release (July 2019)

Statistics on APAs for 2018

An APA is an agreement between a taxpayer and the tax authority of a country to provide advance certainty concerning the transfer pricing methodology. APAs simplify or prevent costly and time-consuming tax examinations into the transactions at issue. The EC receives on an annual basis certain information about APAs from the EU Member States including:

  • Total number of APAs in force at the end of the year: EU (726) and non-EU (515)
  • Total number of bilateral and multilateral APAs in force at the end of the year: EU (116) and non-EU (155)
  • Total number of unilateral APAs in force at the end of the year: EU (610) and non-EU (360)
  • Number of APA requests received in the year: EU (778) and non-EU (327)
  • Number of APAs granted in the year: EU (520) and non-EU (193)
  • Number of APAs rejected in the year: EU (25) and non-EU (6)
  • Number of APAs when the taxpayer withdrew its request in the year: EU (79) and non-EU (17)
  • Average time in months to negotiate bilateral or multilateral APAs for each country

Read the EC report (July 2019) of APA statistics for 2018 [PDF 341 KB]

Statistics on MAPs for 2018

The EU Arbitration Convention established a procedure to resolve transfer pricing disputes between EU Member States involving double taxation (the result of an upward adjustment to the profits of an enterprise in an EU Member State that is not followed by an equivalent downward adjustment in the other EU Member State). The Arbitration Convention provides for a dispute settlement procedure at the first stage—that is, mutual agreement procedure (MAP). The EC receives on an annual basis from the EU Member States on pending MAPs at the end of each year, including:

  • Outstanding MAPs at the end of each year
  • Reasons why cases are pending two years after initiation
  • Reasons for rejection either by the reporting EU Member State or the other EU Member State
  • Time from the date of submission of the MAP request to the date on which a case is initiated

The statistics report only addresses MAPs between EU Member States, not with third countries.

Read the EU report (July 2019) of MAP statistics for 2018 [PDF 335 KB] 

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