24/01/2023 – Following the successful completion of peer reviews under the existing BEPS Action 14 Assessment Methodology, the OECD/G20 Inclusive Framework on BEPS has agreed a new Assessment Methodology for continuing the robust peer review process that seeks to increase efficiencies and improve the timeliness of the resolution of double taxation disputes. In addition, the Inclusive Framework has also agreed new data points to be reported in the annual Mutual Agreement Procedure (MAP) Statistics and the creation of a new annual framework for reporting Advance Pricing Arrangement (APA) Statistics. Discussions on changes to the BEPS Action 14 minimum standard are still ongoing.
BEPS Action 14 Assessment Methodology
The new Assessment Methodology for the Action 14 peer reviews includes:
Further details on these processes are available in the revised Assessment Methodology.
MAP Statistics Reporting Framework
To provide a clearer picture of their MAP practices and to improve transparency, jurisdictions will report the additional data points below concerning post-2015 MAP cases in their MAP Statistics:
These data points will be reported by all Inclusive Framework member jurisdictions from the 2023 MAP Statistics (expected to be available in 2024) onwards. Further details on these new data points are available in the revised MAP Statistics Reporting Framework.
APA Statistics Reporting Framework
In line with the progress that has been achieved in the area of APAs through the Bilateral Advance Pricing Arrangement Manual (BAPAM), Inclusive Framework members that have an APA programme will report annual statistics with respect to APAs (APA Statistics) which will be published on the OECD website in a common format, while allowing jurisdictions some flexibility to follow their own reporting rules. The APA Statistics will be available from 2024 onwards. Further details on the newly agreed rules for reporting APA Statistics are available in the APA Statistics Reporting Framework.
Further information on the work done with respect to dispute resolution, including MAP and BEPS Action 14, is available at www.oecd.org/tax/dispute/.
Media enquiries should be directed to Grace Perez-Navarro, Director of the OECD Centre for Tax Policy and Administration (+33 1 45 24 18 80) or Achim Pross, Deputy Director of CTPA (+33 1 45 24 98 92).