Competent authorities resolved a record 2971 cross-border tax disputes through the Mutual Agreement Procedure (MAP) in 2025, 17.6% more than in 2024, while reducing the time needed to close cases, according to new statistics released today by the OECD. These figures also show increased use of Advance Pricing Arrangements (APAs) to prevent transfer pricing disputes before they arise, supporting efforts to reduce double taxation and enhance tax certainty for cross-border investment.
The 2025 MAP Statistics*, covering 137 jurisdictions of the OECD/G20 Inclusive Framework on BEPS, show that MAP cases were also resolved more quickly, with the average time required to close a case falling by 6.2%, from 27.37 months in 2024 to 25.66 months in 2025. The average for non-transfer pricing cases returned below the 24-month target, while completion times for transfer pricing cases also improved.
As closures grew faster than new cases, the year-end MAP inventory declined by 0.8% to 6 113 cases, reversing the increase recorded in 2024. Non-transfer pricing cases drove this reduction: closures increased by 26.7%, reducing the corresponding inventory by 3.7%. For transfer pricing cases, closures increased by 6% and new cases declined by 2.4% as compared to 2024. However, because new cases continued to outnumber closures in 2025, the year-end inventory increased by 2.1%. Inventory growth nevertheless slowed from 3.9% in 2024.
Competent authorities also continued to reduce the number of longstanding cases. Cases predating 2016, or the relevant jurisdiction’s membership of the OECD/G20 Inclusive Framework on BEPS, fell by approximately 41% and represented less than 4% of the remaining inventory. Around 57% of open post-2015 cases were less than two years old. Overall, 75.9% of reported outcomes resolved the issue raised by the taxpayer through a full agreement, unilateral relief, or a domestic remedy, while only 4.1% involved cases concluded without an agreement between competent authorities.
These results reflect sustained efforts by competent authorities to resolve cases more efficiently, address older cases, and improve the practical functioning of MAP, supported by the BEPS Action 14 peer review process and guidance, including the Manual on Effective Mutual Agreement Procedures.
The 2025 APA Statistics* show that jurisdictions granted 943 bilateral APAs in 2025, 11.6% more than in 2024, while the year-end inventory increased by 3.2% to 4 334 cases. By contrast, the number of APA applications and the average time required to grant an APA remained broadly stable at 1 168 new applications and 40.19 months, respectively. The results demonstrate both the continued importance and use of bilateral APAs in preventing transfer pricing disputes and the need for further progress on the efficiency and timeliness of APA programmes.
The MAP and APA Statistics form part of the BEPS Action 14 minimum standard and the wider OECD/G20 tax certainty agenda, providing a global frame of reference for assessing progress. They were released during OECD Tax Certainty Day 2026, which brought together tax officials, business representatives, and other stakeholders to discuss the role of tax certainty in promoting stability, confidence, and trust, dispute prevention, and the future of MAP and APA administration in an evolving international tax landscape.
The OECD also announced the results of the 2025 MAP and APA Awards, recognising jurisdictions that delivered exceptional performance in tax dispute resolution and prevention. Denmark and New Zealand received awards for the fastest completion times for transfer pricing cases and other MAP cases, respectively. Norway received the new award for the youngest MAP inventory and was also recognised for the most effective caseload management in the medium inventory category, while the Netherlands received the caseload management award in the large inventory category. Denmark-Germany and Jersey-United Kingdom were recognised for outstanding collaboration and efficiency in joint case handling, and Germany was also named the most improved MAP jurisdiction. Finally, in the APA category, Finland achieved a double distinction, receiving both awards for greatest improvement and effective caseload management.
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.
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