22/11/2021 – As 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 OECD released today the latest mutual agreement procedure (MAP) statistics covering 118 jurisdictions and practically all MAP cases worldwide.
Dispute resolution mechanisms, including MAPs, are the cornerstone of a well-functioning tax treaty network. The BEPS Action 14 Minimum Standard adopted in 2015 by the members of the OECD/G20 Inclusive Framework on BEPS seeks to improve the resolution of tax-related disputes between jurisdictions and includes a peer review mechanism to monitor the compliance of member jurisdictions with this minimum standard.
The 2020 MAP Statistics* and the 2020 MAP Awards were presented during the third OECD Tax Certainty Day where tax officials and stakeholders took stock of the tax certainty agenda and discussed ways to further improve dispute prevention and resolution. MAP Statistics play an important role in the monitoring of BEPS Action 14, providing 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. The 2020 MAP Statistics* show the following trends:
This year's MAP Awards, given in recognition of particular efforts by competent authorities, saw the following winners: Switzerland and Australia for the shortest time in closing transfer pricing cases and other cases respectively; Spain for the smallest proportion of pre-2016 cases in end inventory; and Luxembourg and Norway for the most effective caseload management. The award for the pairs of jurisdictions that dealt the most effectively with their joint caseload went to Italy-Spain for transfer pricing cases and to Norway-Sweden for other cases. Finally, the award for the most improved jurisdiction, which also highlights the efforts taken by competent authorities to resolve MAP cases during the COVID-19 crisis, went to Ireland.
Media enquiries should be directed to Pascal Saint-Amans, Director of the OECD Centre for Tax Policy and Administration (+33 1 45 24 91 08) or Achim Pross, Head of the International Co-operation and Tax Administration Division (+33 1 45 24 98 92).
*Please refresh your web browser if 2019 data is visible.