18/11/2020 – As part of the BEPS Action 14 minimum standard and the wider G20/OECD tax certainty agenda to improve the effectiveness and timeliness of tax-related dispute resolution mechanisms, the OECD releases today the latest mutual agreement procedure (MAP) statistics covering 105 jurisdictions and almost all MAP cases worldwide.
The 2019 MAP Statistics* and the 2019 MAP awards were presented during the second OECD Tax Certainty Day where tax officials and stakeholders from over 60 jurisdictions took stock of the tax certainty agenda and discussed ways to further improve dispute prevention and resolution. The discussions, which took place against the backdrop of the economic effects of the COVID-19 crisis, covered a wide range of tax certainly tools, including advance pricing arrangements, the International Compliance Assurance Programme (ICAP), bilateral and multilateral MAPs and the Forum on Tax Administration’s work on benchmarking.
Dispute resolution mechanisms, including MAPs, are the cornerstone of a well-functioning tax treaty network. The BEPS Action 14 Minimum Standard adopted in 2015 by the members of the OECD/G20 Inclusive Framework on BEPS seeks to improve the resolution of tax-related disputes between jurisdictions and includes a peer review mechanism to monitor the compliance of member jurisdictions with this minimum standard.
On the basis of the experience gained during the peer reviews (with 82 jurisdictions reviewed and 1500 recommendations issued), the OECD Secretariat has developed proposals to strengthen the BEPS Action 14 Minimum Standard on which stakeholder input would be welcome. These proposals relate to all aspects of the MAP process (dispute prevention, access to MAP, resolution of MAP cases and implementation of MAP agreements) as well as to the MAP Statistics Reporting framework. As taxpayers are the main users of the MAP, their input on these proposals will be key.
MAP Statistics play an important role in the monitoring of BEPS Action 14, providing an objective and global frame of reference, as well as a country specific view, which together allow measurement of progress but also show where further work is needed. The 2019 MAP Statistics* show the following trends:
This year's MAP Awards, given in recognition of particular efforts by competent authorities, saw the following winners: Japan for the shortest time in closing transfer pricing cases, ex-aequo with the United Kingdom, who also won the prize for other cases. Belgium for the smallest proportion of pre-2016 cases in end inventory and Belgium and Norway for the most effective caseload management. The collaborative award for the pairs of jurisdictions that dealt the most effectively with their joint caseload were India-Japan for transfer pricing cases and Norway-United States for other cases.
Media enquiries should be directed to Pascal Saint-Amans, Director of the OECD Centre for Tax Policy and Administration (+33 1 45 24 91 08) or Achim Pross, Head of the International Co-operation and Tax Administration Division (+33 1 45 24 98 92).
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