Insights
OECD releases 2017 Mutual Agreement Procedure statistics
The OECD’s work to advance tax certainty specifically includes 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. As part of this work, the OECD makes available to the public, via its website, annual statistics on the MAP caseloads of all its member countries and of non-OECD economies that agree to provide such statistics.
The OECD published MAP statistics for the 2017 reporting period available in October 2018. The report covers opening and ending inventory of MAP cases for 2017, the number of new MAP cases initiated, the number of MAP cases completed, cases closed or withdrawn, and the average cycle time for cases completed, closed or withdrawn cases.
• Overall 2017 inventory: Statistics indicate there was 7,500 open cases reported for the period, with 2,745 cases completed, 2,076 new cases started and 6,831 cases left at the end of the year. New transfer pricing cases are up by 25% and other cases up by 50%.
• Timelines: Transfer pricing cases take on average more time to complete than other cases with an average of 30 months for transfer pricing cases and 17 months for other cases.
• Outcomes: Most of the MAPs concluded in 2017 resolved the issue for transfer pricing cases. Of these transfer pricing MAP cases, around 65% were resolved with an agreement fully eliminating double taxation and almost 15% of them were granted a unilateral relief.
The table below provides a summary of the OECD’s statistics on MAPS in the EU at the end of 2017. The table sets out the open, new, finalized and closing number of transfer pricing and other MAPs. For further information relating to the MAP Statistics in the EU and worldwide, please refer to the OECD’s website and our Deloitte Global Transfer Pricing Alert:
Table 1 : EU’s MAP Statistics for the period ending December 2017
| Country | 2017 open inventory | Cases started in 2017 | Cases finalised in 2017 | 2017 closed inventory |
| Austria | 243 | 81 | 69 | 255 |
| Belgium | 773 | 502 | 537 | 738 |
| Bulgaria | 17 | 3 | 4 | 16 |
| Czech Republic | 44 | 13 | 8 | 49 |
| Denmark | 181 | 72 | 60 | 193 |
| Estonia | 1 | 4 | 1 | 4 |
| Finland | 111 | 45 | 42 | 114 |
| France | 837 | 336 | 291 | 882 |
| Germany | 1181 | 582 | 522 | 1241 |
| Greece | 29 | 10 | 11 | 28 |
| Hungary | 20 | 5 | 5 | 20 |
| Iceland | 0 | 3 | 2 | 1 |
| Ireland | 43 | 11 | 12 | 42 |
| Italy | 439 | 206 | 62 | 583 |
| Latvia | 2 | 1 | 1 | 2 |
| Liechtenstein | 10 | 5 | 3 | 12 |
| Lithuania | 3 | 3 | 1 | 5 |
| Luxembourg | 267 | 250 | 347 | 170 |
| Monaco | 0 | 0 | 0 | 0 |
| Norway | 76 | 42 | 37 | 81 |
| Poland | 109 | 70 | 50 | 129 |
| Portugal | 60 | 23 | 34 | 49 |
| Romania | 26 | 12 | 3 | 35 |
| Slovak Republic | 28 | 5 | 2 | 31 |
| Spain | 280 | 112 | 117 | 275 |
| Sweden | 181 | 114 | 87 | 208 |
| Switzerland | 366 | 169 | 197 | 338 |
| United Kingdom | 319 | 344 | 206 | 457 |
| 5646 | 3023 | 2711 | 5958 |
In relation to Ireland, the MAP statistics indicate that during the period there were 43 open cases, 11 new cases, 12 cases finalized and 42 ongoing cases. The below graph sets out Ireland’s MAPs statistics for the period ending 2017.
Table 2 : Ireland’s MAP Statistics for the period ending December 2017
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