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 non-OECD economies that agree to provide such statistics. MAP statistics are now available for the 2014 reporting period.
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, 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 2014 reporting period (MAP statistics were provided earlier for reporting periods 2006 through 2013). Considered in the aggregate, MAP inventories in OECD member countries at the end of these reporting periods show a continuous increase from 2006 to 2014, with a slight decrease in 2010. For those countries that reported them, the average cycle times for cases completed, closed or withdrawn increased slightly in 2014 (23.79 months) as compared to 2013 (23.57). The separation of reported MAP cases into cases with other OECD member countries and cases with non-OECD economies continues to show, in general, that more than 90% of OECD member countries' MAP inventories are cases with other OECD member countries.
Improving the effectiveness of dispute resolution mechanisms was an integral component of the work on BEPS and was the aim of Action 14 of the BEPS Action Plan (read the final 2015 Report on Action 14 of the BEPS Action Plan). One of the principal outcomes of the work on Action 14 is the commitment by OECD and G20 countries to a minimum standard with respect to the resolution of treaty-related disputes. As part of the Action 14 minimum standard, countries have agreed to report MAP statistics pursuant to an agreed reporting framework; such reporting will provide a tangible measure of the effects of the implementation of the minimum standard. The MAP statistics made available for later periods will accordingly contain additional information and will include reports from non-OECD economies countries that do not currently report MAP statistics to the OECD.
Bron: OECD
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