At the 7th OECD Tax Certainty Day held today, the OECD released new statistics on Mutual Agreement Procedures (MAPs) and Advance Pricing Arrangement (APAs), providing a comprehensive view of how jurisdictions resolve cross-border tax disputes and prevent double taxation.
The 2024 MAP Statistics cover a record 141 jurisdictions and practically all MAP cases worldwide for 2024. Resolution times remain broadly stable in 2024 at 27.4 months on average, with transfer pricing cases slightly improved at 30.9 months (down from 32 in 2023) and other cases at 24.5 months (up from 23.4 in 2023). The data also shows that 76% of MAP cases reached full resolution, up from 74% in 2023, while only 4% were closed without agreement, clearly demonstrating the dedication with which competent authorities seek to reach agreements in most cases. Notably, although the number of closed cases has dipped, competent authorities continue to make substantial progress in reducing aged inventory: only 3.3% of cases predate 2016, fewer than 20% are older than four years, and over 56% are under two years, marking a clear improvement over 2023.
The results also show a small increase in case inventory, with transfer pricing cases up by 3.9% and other cases by 2.7%. This signals a return to the trend line in inventory, particularly for transfer pricing cases, following a brief dip in 2023, possibly reflecting the fading impact of COVID-19 on adjustments that go to MAP. The number of closed MAP cases declined by 2.8% following a record high number of closures in 2023, driven by a 5.5% drop in closed transfer pricing cases. This return to the trend line also underscores the continued importance of the broader tax certainty agenda covering simplification as well as dispute prevention and resolution.
In parallel, the use of bilateral APAs continues to expand as a key tool for dispute prevention. According to the 2024 APA Statistics also released today, 80 jurisdictions reported allowing bilateral APAs, up from 73 in 2023, with 49 actively managing cases. In 2024, the number of bilateral APAs filed rose by 3%, and roughly a quarter of the inventory was closed, consistent with 2023. Notably, jurisdictions continue to prioritise dispute prevention, with several of them reporting that APAs account for more than half of their bilateral transfer pricing caseload. Eleven jurisdictions even achieve ratios of over 50%, while the overall average ratio is 37.8%.
APAs granted were slightly down by 2%, while rejections or closures without agreement rose from 12% to over 19%. In addition, the average time to grant APAs increased to 39.6 months in 2024 (up from 36.8 months in 2023). Looking more granularly, the data shows that several jurisdictions have significantly enhanced the performance of their APA programmes, exceeding past records for bilateral APA approvals, with a growing number entering into multilateral APAs. Overall the APA statistics clearly justify the continued emphasis of the Forum on Tax Administration MAP Forum on dispute prevention tools as well as the importance of the best practices outlined in the Bilateral APA Manual.
The 2025 OECD Tax Certainty Day gathered competent authorities and stakeholders from business and academia across the globe to take stock of the tax certainty agenda, through panels reflecting on the tax certainty journey, considering simplification as a means to certainty, sharing good practices in dispute prevention, exploring global perspectives on MAPs and APAs, and discussing capacity-building for jurisdictions new to the process.
The OECD also announced the results of the 2024 MAP and APA Awards, recognising jurisdictions that achieved notable performance in resolving cases efficiently and collaboratively. Switzerland and New Zealand received awards for the shortest time in closing transfer pricing cases and other cases respectively; Mexico was honoured for having no pre-2016 cases in end inventory; and Netherlands and Norway were recognised for the most effective caseload management. India-Japan and Australia-New Zealand were awarded as pairs for their efficiency in joint case handling and the United States earned the award for the most improved jurisdiction. Finally, two new APA awards were granted this year: Ireland earned the most improved jurisdiction award, while Denmark was honoured for the most effective caseload management.
The OECD also released today a preliminary version of the 2025 update of the Consolidated Information on Mutual Agreement Procedures.
These releases and the statistics contribute to the OECD/G20 tax certainty agenda and reinforce the BEPS Action 14 Minimum Standard by enhancing transparency and supporting continued improvement of tax-related dispute resolution mechanisms.
Updated datasets, charts, and a summary of key insights on the statistics are available on the OECD website.
Further enquiries should be directed to the Communications Office of the OECD Centre for Tax Policy and Administration.
