By Julie Martin, MNE Tax
Despite the efforts of the OECD and others enhance tax certainty, the number of new tax disputes between multinational groups and governments continued to increase in 2019, according to the OECD’s latest statistics, released today.
In 2019, the number of times that taxpayers needed to resort to the mutual agreement procedure (MAP) in a tax treaty to resolve a transfer pricing dispute increased by more than 20 percent as compared to 2018, OECD said in a release analyzing the new statistics.
The number of 2019 MAP cross-border tax disputes not involving transfer pricing increased by 10 percent as compared to the prior year, the OECD said.
The new statistics assess the performance of about 100 countries that are members of the “Inclusive Framework on BEPS,” covering almost all MAP cases worldwide.
Germany had the greatest number of new MAP cases in 2019, with 659 new cases filed, the new data revealed. This was followed by the US with 350 new filings; France with 381; and India, with 2016 new cases.
The country with the largest overall MAP caseload at the end of the reporting period was Germany, with 1,242 tax disputes pending. This was followed by the US, which had 1,022 cases; by India, with 951; by France with 902; and by Italy with 887.
In comparison, at the end of 2018, Germany had the largest number of pending cases, 1198, followed by the US with 1007, and France at 972.
This year, the OECD presented MAP statistics during an event called “tax certainty day,” attended virtually by the tax authorities of more than 60 nations.
The OECD handed award to countries to recognize their efforts the area of cross-border tax dispute resolution, as revealed in the new OECD stats.
Japan’s and the UK’s tax authority tied for an award that recognized the shortest time taken to close transfer pricing cases among those countries that closed more than than 50 transfer pricing cases in 2019. Japan and the UK both averaged 21 months to close these cases. This was followed by Switzerland, which closed transfer pricing cases, on average, in 23 months.
The UK won a similar award for the shortest time to resolve non-transfer pricing cases, this time competing with countries that closed more than 20 “other” cases in 2019.
Time to complete the non-transfer pricing cases was 6 months for the UK. Norway had the second best performance, closing non-TP cases in 11 months.
The following stats and other material were released:
- 2019 MAP caseload per jurisdiction
- 2019 MAP caseload per jurisdiction for transfer pricing cases
- 2019 MAP caseload per jurisdiction for other cases
- Evolution of MAP inventory per jurisdiction
- Interactive dataviz tool
Julie Martin
Julie Martin is the founder of MNE Tax. She edits the publication and regularly contributes articles on new developments in cross-border business taxation.
Julie has worked as a tax journalist and editor for more than 13 years. Prior to that, she worked as an in-house tax attorney in New York. She also holds an LLM in taxation from New York University School of Law.
Julie can be reached at [email protected].
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Thank for this summary and the links.