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OECD: Report of MAP statistics for 2019

OECD: Report of MAP statistics for 2019

The Organisation for Economic Cooperation and Development (OECD) today released the most recent mutual agreement procedure (MAP) statistics covering 105 jurisdictions and almost all MAP cases worldwide.

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According to the OECD release, the 2019 MAP statistics released today provide detailed information, summarized by the OECD as follows:

  • An increase in the number of MAP cases initiated—Approximately seven MAP cases were started every day in 2019 (three being transfer pricing cases and four in other cases) for approximately 2,700 new cases in 2019 (up at least 20% for transfer pricing cases and more than 10% for other cases). The number of MAP cases has nearly doubled since 2016, and it is expected this trend could continue with no significant reduction in MAP activity expected (despite the COVID-19 crisis).
  • An increase in the number of MAP cases closed—Competent authorities closed more cases in 2019 than in 2018. Still, MAP case inventories are increasing in the majority of jurisdictions, despite the fact that competent authorities have increased their capacity and closed approximately 50% more transfer pricing cases and 70% more other cases in 2019 when compared to the statistics for 2016.
  • Transfer pricing case resolution—Approximately 85% of the MAPs concluded for transfer pricing cases in 2019 fully resolved the issue (compared to 80% in 2018).
  • Time to conclude MAP cases—On average, the time to close MAP cases in 2019 was 25 months (31 months for transfer pricing cases, 22 months for other cases). More than one-fifth of the 2019 year-end inventory has been pending for more than four years. 

Request for comments on 2020 review of BEPS Action 14

According to the OECD release, the OECD is seeking public comments on the 2020 review of BEPS Action 14, Making dispute resolution mechanisms more effective. Comments are requested by Friday, 18 December 2020.

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