OECD: Mutual Agreement Procedure Stats (2013)

Par Robert Robillard - 26 novembre 2014

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Gratte-ciel

As expected, MAP inventories keep rising…

The number of new cases basically doubled between 2006 and 2013. The number of year-end cases has also doubled in the same period.

For Canada, the number of new cases went from 76 to 127 and the year-end balance from 134 to 235 (in a period of Competent Authority budget-cuts; ouch!). In the United states, numbers are 240 to 403 (new cases) and 430 to 732 (year-end cases).

See all the 2013 stats here.

Past year stats are available here.

Now, wait until BEPS starts making its impact…

From the OECD website:

« 25/11/2014 – As part of the OECD’s work to improve the timeliness of processing and completing mutual agreement procedure (MAP) cases under tax treaties and to enhance the transparency of the MAP process, the OECD makes available to the public, via its website, annual statistics on the MAP caseloads of all its member countries and of Partner economies that agree to provide such statistics. MAP statistics are now available for the 2013 reporting period.

Mutual Agreement Procedure Statistics for 2013

The MAP reporting framework and the definitions of terms used in reporting, as well as the other results of the proposals in the Committee on Fiscal Affairs’ (CFA) 2004 report on improving the resolution of cross-border tax disputes (“Improving the Process for Resolving International Tax Disputes”), are described in detail in the CFA’s 2007 report “Improving the Resolution of Tax Treaty Disputes”.

The MAP statistics now made available correspond to the 2013 reporting period (MAP statistics were provided earlier for reporting periods 2006 through 2012). Considered in the aggregate, MAP inventories in OECD member countries at the end of these reporting periods show a continuous increase from 2006 to 2013, with a slight decrease in 2010. For those countries that reported them, the average cycle times for cases completed, closed or withdrawn decreased in 2013 (23.57 months) as compared to 2012 (25.46 months). The separation of reported MAP cases into cases with other OECD member countries and cases with Partner economies continues to show, in general, that more than 90% of OECD member countries’ MAP inventories are cases with other OECD member countries.

The OECD intends to continue to collect and make available MAP statistics from later periods as such information becomes available, which will provide useful information on longer-term trends in MAP caseloads. The collection of this data will inform the work the OECD is doing to improve dispute resolution processes such as the Multilateral Strategic Plan on Mutual Agreement Procedures recently launched by the Forum on Tax Administration and Action 14 of the BEPS Action Plan, which aims to make dispute resolution mechanisms more effective. »

Robert Robillard, CPA, CGA, MBA, M.Sc. Econ.
Transfer Pricing Chief Economist, RBRT Inc.
514-742-8086; robert.robillard « at » localhost
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