The OECD reports that competent authorities resolved a record 2,971 cross-border tax disputes through the Mutual Agreement Procedure (MAP) in 2025, a 17.6% increase from 2024. Average resolution times fell and the overall case backlog declined, while bilateral Advance Pricing Agreement (APA) grants also increased.
The OECD has released new tax dispute statistics on 4 November 2026 as part of Tax Certainty Day 2026, showing that tax disputes were resolved more quickly and Mutual Agreement Procedure (MAP) closures reached a record high in 2025.
Competent authorities resolved a record 2,971 cross-border tax disputes through the Mutual Agreement Procedure (MAP) in 2025. That is 17.6% more than in 2024, and the cases closed faster. The OECD released the figures, which cover 137 jurisdictions in the OECD/G20 Inclusive Framework on BEPS.
Cases close faster and the backlog shrinks
The average time to close a MAP case fell 6.2%, from 27.37 months in 2024 to 25.66 months in 2025. Cases that do not involve transfer pricing now average below the 24-month target. Transfer pricing cases also moved faster.
Closures outpaced new cases, so the year-end inventory fell 0.8% to 6,113 cases. Closures of non-transfer pricing cases rose 26.7%, which cut that inventory by 3.7%. Transfer pricing closures rose 6%, while new transfer pricing cases fell 2.4%. New cases still outnumbered closures in that category, so its inventory grew 2.1%. That growth was slower than the 3.9% rise seen in 2024.
Older cases also declined. Cases opened before 2016, or before the relevant jurisdiction joined the Inclusive Framework, fell by about 41%. They now make up less than 4% of the remaining inventory. Around 57% of open cases from 2016 onward are less than two years old.
Taxpayers gained relief in most cases. Of the reported outcomes, 75.9% resolved the taxpayer’s issue through a full agreement, unilateral relief, or a domestic remedy. Only 4.1% ended without an agreement between competent authorities.
Advance pricing arrangements gain ground
Jurisdictions granted 943 bilateral Advance Pricing Arrangements (APAs) in 2025, 11.6% more than in the previous year. The year-end APA inventory rose 3.2% to 4,334 cases. New applications held roughly steady at 1,168, and the average time to grant an APA stayed near 40.19 months. The statistics show that bilateral APAs remain widely used, but the process still needs to become faster.
Awards recognise top performers
The OECD also presented the 2025 MAP and APA Awards. Denmark won for the fastest completion of transfer pricing cases, and New Zealand won for the fastest completion of other MAP cases. Norway received a new award for the youngest MAP inventory and also won for effective caseload management in the medium inventory category. The Netherlands took the caseload management award in the large inventory category.
Denmark and Germany, along with Jersey and the United Kingdom, earned recognition for joint case handling. Germany was also named the most improved MAP jurisdiction. In the APA category, Finland won two awards, one for greatest improvement and one for effective caseload management.
