by Julie Martin, MNE Tax
The OECD has released 2017 mutual agreement procedure (MAP) program statistics, providing details on how quickly and effectively 85 countries, including all OECD and G20 countries, resolve their tax treaty disputes.
The data was obtained from countries that have joined a coalition of countries seeking to fight tax avoidance and improve cross-border tax dispute resolution called the “Inclusive Framework on BEPS.” Inclusive Framework countries have agreed to report to the OECD statistics relating to their MAP programs using a standardized reporting method so that the country data can be compared. The expectation is that the fear of negative publicity will encourage lagging countries to improve their tax dispute resolution processes.
The 2017 stats break down each country’s MAP program cases into transfer pricing and other allocation/attribution cases and other cases and report on both using the agreed-to methodology. In addition, aggregated information is provided.
According to an OECD release, the statistics show that although tax administrations in 2017 resolved more MAP program disputes than ever before, the number of outstanding cases also increased because the number of new disputes increased.
Transfer pricing cases increased by 25 percent since the 2016 reporting period and transfer pricing disputes continue to take more time to resolve than other cases, the OECD noted.
Moreover, the OECD said that while Inclusive Framework member countries have pledged to close MAP program cases within 24 months, only 60 percent of the reporting countries met that target for all cases in 2017.
While the Inclusive Framework is now comprised of 119 member countries, the 2017 MAP statistics only cover Inclusive Framework members that joined before 2018.
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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