The Organisation for Economic Co-operation and Development (OECD) published the 2023 Mutual Agreement Procedure (MAP) Statistics and Advance Pricing Agreement (APA) Statistics on 15 November 2024.

The OECD also presented MAP and APA awards to tax administrations for their remarkable contributions to enhancing tax certainty.

MAP statistics

The Mutual Agreement Procedure (MAP) is a treaty-based process that enables tax administrations to negotiate and resolve issues of double taxation or other tax matters that do not align with the terms of an applicable tax treaty.

The MAP 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 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.

All members of the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) commit to the implementation of the Action 14 minimum standard, which includes timely and complete reporting of mutual agreement procedure (MAP) statistics pursuant to an agreed reporting framework. The 2023 MAP statistics are reported under this new framework. They cover all the members that joined the Inclusive Framework before 2024.

APA 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 gives stakeholders a more complete picture of a jurisdiction’s approach to preventing and resolving transfer pricing disputes.

OECD’s APA statistics offer insight into global APA inventories and completion times despite being less detailed than MAP statistics and IRS releases. In 2023, while MAP inventories declined, pending APAs increased to 4,080, highlighting the continued need for tax certainty.

2023 MAP & APA Awards

On the occasion of the sixth Tax Certainty Day, the OECD announced the winners of the MAP and APA awards for this year, noting that the APA statistics were filed for the first time. The winners for all categories have been determined by taking into account the time necessary and the outcomes reached in MAP and APA by the jurisdictions concerned as well.

OECD included five categories under MAP, such as

The Netherlands and Australia excelled in speed, while Canada led in the case inventory age. The Netherlands and Norway topped caseload management. Canada with France and Austria with Switzerland excelled in cooperation. France achieved the most improvements, and Japan won in dispute prevention under APA.