Starting with the 2006 reporting period, the OECD has compiled annual statistics on the mutual agreement procedure (MAP) caseloads of all its member countries and of non-OECD economies that agree to provide such statistics. Statistics are available for each of the countries listed below.
The statistics for each reporting period (generally a calendar year) include:
- opening inventory of MAP cases on the first day of the reporting period;
- number of MAP cases initiated during the reporting period;
- number of MAP cases completed during the reporting period;
- ending inventory of MAP cases on the last day of the reporting period;
- cases closed or withdrawn with double taxation during the reporting period; and
- average cycle time for cases completed, closed or withdrawn during the reporting period.
In addition, starting with the 2008 reporting period, the statistics of some countries divide MAP cases into cases with OECD member countries and cases with non-OECD economies for countries that have provided that information. More information on the MAP reporting framework, including the definitions of terms used in reporting, can be found in the 2007 Report “Improving the Resolution of Tax Treaty Disputes” (see also the relevant News Release on the 2007 Report).
The latest statistics available correspond to the 2008 and 2009 reporting periods. These statistics reveal that at the end of the 2009 reporting period, the total number of open MAP cases reported by OECD member countries was 3413, a 17.8 % increase as compared to the 2008 reporting period and a 45.1 % increase as compared to the 2006 reporting period (MAP cases involving two OECD member countries are double-counted in this total). For the OECD member countries for which data was provided, the average time for the completion of MAP cases with other OECD member countries was 22.82 months in the 2009 reporting period, 22.42 months in the 2008 reporting period, 18.93 months in the 2007 reporting period and 22.10 months in the 2006 reporting period.