Following the progress achieved in the area of Advance Pricing Arrangements (APAs) through the Bilateral Advance Pricing Arrangement Manual (BAPAM), the OECD published the Advance Pricing Arrangement (APA) Statistics Reporting Framework in 2023. This framework showcases Inclusive Framework (IF) members’ efforts to increase tax certainty through dispute prevention, in addition to all the work that has been done on the dispute resolution side. Under the new framework, all BEPS Inclusive Framework member jurisdictions with bilateral or multilateral APA programs, or that can enter such agreements under their domestic laws or tax treaties, commit to reporting APA Statistics based on agreed criteria, while retaining the flexibility to use their own reporting cycles and definitions for “Start Date” and “End Date” when calculating the average time to close APA cases. Reporting jurisdictions are not required to align their APA Statistics with those of their treaty partners. The 2025 APA Statistics are published under this framework and include data from all relevant IF members that joined the Inclusive Framework prior to 2026.
2025 Advance Pricing Arrangement Statistics
In line with the OECD/G20 tax certainty agenda, which promotes dispute prevention, APA Statistics are a new metric designed to provide a clearer, more accurate view of a jurisdiction’s dispute prevention and resolution efforts, enhancing transparency in this area. When read alongside MAP Statistics, APA Statistics give stakeholders a more complete picture of a jurisdiction’s approach to preventing and resolving transfer pricing disputes.
At a glance
| 2025 Start inventory | Cases started | Cases closed | 2025 End inventory | Average time taken in months to grant APAs during the reporting period | |||
|---|---|---|---|---|---|---|---|
| Granted | Rejected | Other reason | |||||
| APA cases | 4285 | 1168 | 943 | 23 | 155 | 4334 | 40.19 |
Jurisdictions are taking efforts to conclude APAs relative to their inventory
Note: The closing ratio measures the number of APA cases closed by each jurisdiction during the reporting year as compared its total APA caseload. This is calculated by taking the percentage of the number of APA cases closed during the year over the sum of (i) the number of APA cases in inventory at the beginning of the year and (ii) half of the number of APA cases that started during the year. The number of APA cases started during the reporting year is halved in this ratio as some of the APA cases started may have started towards the end of the year, making it unreasonable to expect jurisdictions to have closed such cases. This adjustment also explains that the ‘closing ratio’ may be higher than 100% for some jurisdictions.
Jurisdictions are prioritising dispute prevention in transfer pricing cases
Note: This figure takes into account the number of APA cases granted and in the end inventory compared to the number of transfer pricing MAP cases closed and in end inventory.
Breakdown per reporting jurisdiction
Only IF members that already have a bilateral/multilateral APA programme or can enter into such APAs under domestic law and/or tax treaties should report their annual APA statistics.
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The following jurisdictions declared allowing bilateral APAs but reported not being involved in any such cases in the 2025 reporting period: Aruba, Azerbaijan, Benin, Brunei Darussalam, Costa Rica, Croatia, Curaçao, Dominican Republic, Estonia, Eswatini, Faroe Islands, Jamaica, Kazakhstan, Maldives, Moldova (Republic of), Nigeria, Peru, Saint Vincent and the Grenadines, Sri Lanka, Tunisia, Ukraine, Uruguay, and Uzbekistan.
This interactive ‘compare-your-country’ map allows users to see, for the 2025 reporting period, which jurisdictions were allowed to enter into bilateral APAs, which jurisdictions reported bilateral APA activity and the level of APA activity for each reporting jurisdiction.
Further information
- Bilateral Advance Pricing Arrangement Manual (BAPAM)
- Manual on the Handling of Multilateral Mutual Agreement Procedures and Advance Pricing Arrangements (MoMA)
- Learn more about OECD work on tax certainty, dispute resolution and ICAP
- Contact us by e-mail: ctp.contact@oecd.org
- Follow us on social media: @OECDtax (X) & OECD Tax (LinkedIn)
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