Mutual Agreement Procedure Statistics per jurisdiction for 2022

MAP statistics are available per reporting jurisdiction, for each period that they have provided information.

See the table that summarises the total 2022 MAP statistics caseload per jurisdiction
See the table that summarises the 2022 MAP statistics caseload per jurisdiction for transfer pricing cases
See the table that summarises the 2022 MAP statistics caseload per jurisdiction for other cases

Breakdown per reporting jurisdiction

^Notes:

^{The following jurisdictions were members of the inclusive framework in 2022 but have not submitted their 2022 MAP statistics: Congo (Republic of the), Gabon, Liberia, Mauritania, Montenegro, Paraguay and Sierra Leone.}

^{The "closing ratio" measures the number of MAP cases closed by each jurisdiction during the reporting year as compared to 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 divided by two 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.}

See also the graph that presents the evolution of MAP inventory per jurisdiction.

MAP statistics per jurisdiction - all cases

MAP statistics per jurisdiction - Transfer Pricing cases

The reference to "transfer pricing cases" on this page pertains to "attribution/allocation cases" under the agreed reporting framework. These are MAP cases where the taxpayer's MAP request relates to either:

the attribution of profits to a permanent establishment (see e.g. Article 7 of the OECD Model Tax Convention); or
the determination of profits between associated enterprises (see e.g. Article 9 of the OECD Model Tax Convention).

MAP statistics per jurisdiction - Other cases

Any MAP case that is not a transfer pricing case is considered an "other" MAP case (see also transfer pricing cases).

Evolution of MAP inventory per jurisdiction - Breakdown per type of case

Further information is available:

See the graph that presents the evolution of MAP inventory per jurisdiction for transfer pricing cases.
See the graph that presents the evolution of MAP inventory per jurisdiction for other cases.

Dispute resolution

Mutual Agreement Procedure Statistics per jurisdiction for 2022

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