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Country Mutual Agreement Procedure Statistics

As part of the OECD’s ongoing work to improve the timeliness of processing and completing mutual agreement procedure (MAP) cases under tax treaties and to enhance the transparency of the MAP process, the OECD makes available to the public, via its website, annual statistics on the MAP caseloads of all its member countries and of non-OECD economies that agree to provide such statistics. MAP statistics have now been released for the 2008 and 2009 reporting periods.
 
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• cases closed or withdrawn with double taxation during the reporting period; and
• average cycle time for cases completed, closed or withdrawn during the reporting period.

The data for each reporting period are separated based on the year the relevant MAP cases were initiated. In addition, the statistics for the 2008 and 2009 reporting periods 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 tables below show the number of new MAP cases initiated in 2006 through 2009 and the inventory of open MAP cases at the end of each reporting period for OECD member countries and for certain non-OECD economies that have provided statistics. For detailed country-by-country statistics, please click on the country name for a link to the statistics for that country.

Number of New MAP Cases Initiated by Reporting Period

Inventory of MAP Cases at End of Reporting Period

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.
 
Every effort has been made to ensure that these statistics are accurate but if you find errors or omissions please email us at: ctp.contact@oecd.org.

Related Documents

2007 Report: Improving the Resolution of Tax Treaty Disputes