Dispute resolution

Mutual Agreement Procedure Statistics of transfer pricing cases per jurisdiction for 2021


The reference to 'transfer pricing cases' in this page pertains to "attribution/allocation cases" under 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


The following jurisdictions were members of the inclusive framework in 2021 but have not submitted their 2021 MAP statistics: Angola, Antigua and Barbuda, Congo, Djibouti, Gabon, Liberia, Mauritania, Montenegro, Paraguay, Saint Vincent and the Grenadines, Sierra Leone and Ukraine.

The ‘closing ratio’ measures the number of MAP cases closed by each jurisdiction during the reporting year as compared its total MAP caseload. This is calculated by taking the percentage of the number of MAP cases closed during the year over the sum of (i) the number of MAP cases in inventory at the beginning of the year and (ii) half of the number of MAP cases that started during the year. The number of MAP cases started during the reporting year is divided by 2 as some of the MAP 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.



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