>> Dispute Resolution: Country Mutual Agreement Procedure Statistics
25 November 2010. 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 are now available for the 2008 and 2009 reporting periods. The statistics for these reporting periods now divide MAP cases into cases with OECD member countries and cases with non-OECD economies for countries that have reported that information. Statistics for subsequent reporting periods will be posted on the OECD website as they become available.
In January 2007, the OECD Committee on Fiscal Affairs (CFA) directed that member countries would submit annual reports containing statistical information on their MAP caseloads and approved the reporting framework that had been developed by the OECD Secretariat for that purpose. The MAP reporting framework and the definitions of terms used in reporting, as well as the other results of the proposals in the 2004 CFA report on improving the resolution of cross-border tax disputes (“Improving the Process for Resolving International Tax Disputes”), are described in detail in the CFA’s 2007 report “Improving the Resolution of Tax Treaty Disputes”.
At its January 2010 meeting, the CFA approved a modification of the reporting framework to separate reported MAP cases into cases with other OECD member countries and cases with non-member economies. Such reporting should clarify the extent of double-counting in the overall total number of reported cases; it will also provide useful information on the effectiveness of the MAP process with non-OECD countries.
The MAP statistics now made available correspond to the 2008 and 2009 reporting periods (MAP statistics were provided earlier for the 2006 and 2007 reporting periods.) Considered in the aggregate, MAP inventories in OECD member countries show a strong continuous increase from 2006 to 2009. For those countries that reported them, the average cycle times for cases completed, closed or withdrawn was almost the same in 2006, 2008 and 2009, with a slight decrease in 2007. The separation of reported MAP cases into cases with other OECD member countries and cases with non-member economies shows, in general, that more than 90% of OECD member countries’ MAP inventories are cases with other OECD member countries.
The OECD intends to continue to collect and make available MAP statistics from later periods as such information becomes available, which will provide useful information on longer-term trends in MAP caseloads.
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