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EY Global Tax Controversy Flash Newsletter (Issue 77) | Dispute resolution: OECD reports mixed results across APA and MAP programs globally

13 January 2025

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Tax Alerts, Legislation & Policy, National/Federal Taxation, Transfer Pricing, OECD, Group of Seven, Group of Twenty, Global

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United States, Albania, Andorra, Angola, Argentina, Australia, Austria, Bahamas, Bahrain, Bangladesh, Barbados, Belgium, Bolivia, Botswana, Brazil + 133 more

The OECD's Tax Certainty Day of 15 November 2024 brought together global tax professionals to discuss advancements in tax dispute resolution and prevention. The 2023 Mutual Agreement Procedure statistics, a centerpiece of the session, reflected several different shifts. There was a 16% decrease in new transfer pricing (TP) cases in 2023, but a 2.8% increase in “Other” (i.e., non-transfer pricing) cases. Overall, global inventories of Mutual Agreement Procedure (MAP) cases decreased by 3.8%, with a relatively even split between TP and “Other” cases within that figure.There was an encouraging 7.4% increase in the number of TP MAPs and a 15.8%...