Dispute resolution

Mutual Agreement Procedure Statistics of transfer pricing cases per jurisdiction for 2019


Note: The transfer pricing cases at stake here are referred to "attribution/allocation cases" in the agreed reporting framework. These are MAP cases where the taxpayer's MAP request relates to either:

  1. the attribution of profits to a permanent establishment (see e.g. Article 7 of the OECD Model Tax Convention); or
  2. the determination of profits between associated enterprises (see e.g. Article 9 of the OECD Model Tax Convention).


Breakdown per reporting jurisdiction

Note: The following jurisdictions were members of the inclusive framework in 2019 but have not submitted their 2019 MAP statistics: Albania, Anguilla, Antigua and Barbuda, Armenia, Benin, Botswana, Burkina Faso, Cabo Verde, Cameroon, Congo, Democratic Republic of the Congo, Djibouti, Dominica, Egypt, Eswatini, , Gabon, Grenada
Haiti, Honduras, Jamaica, Jersey, Maldives, Montenegro, Montserrat, Namibia, North Macedonia, Paraguay, Saint Lucia, Saint Vincent and the Grenadines, San Marino, Sierra Leone and Sri Lanka.

* The closing ratio measures the ratio of MAP cases closed by the jurisdiction over its total MAP caseload, where the total MAP caseload is the sum of (i) the number of MAP cases in inventory at the beginning of the year and (ii) the number of MAP cases that started during the year. To take into consideration the fact that the MAP cases started during the year did not start on the exact same date and may have started during the first or the second semester, the latter number is divided by 2. This also explains the fact that the closing ratio may be higher than 100% for some jurisdictions.


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