UK and International Tax news
OECD Issues 2013 Statistics On Mutual Assistance Procedure Cases
Sunday 7th December 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.
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).
The statistics for each reporting period (generally a calendar year) include:
- opening inventory of MAP cases on the first day of the reporting period;
- number of MAP cases initiated during the reporting period;
- number of MAP cases completed during the reporting period;
- ending inventory of MAP cases on the last day of the reporting period;
- cases closed or withdrawn with double taxation during the reporting period; and
- average cycle time for cases completed, closed or withdrawn during the reporting period.
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For those countries that reported them, the average cycle times for cases completed, closed or withdrawn decreased in 2013 (23.57 months) as compared to 2012 (25.46 months).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 indicators on longer-term trends in MAP caseloads.
The collection of this data will assist in 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.Contact Us