Episode 26: Navigating Transfer Pricing and Dispute Resolution: Insights from the 2022 Mutual Agreement Procedure Statistics

Jan 31, 2024

Statistics from Organisation for Economic Co-operation and Development (OECD) on Mutual Agreement Procedures (MAP) for 2022 show that increase in global tax disputes and a more accessible MAP process resulting in more taxpayers seeking relief. The 2022 statistics demonstrate that MAP remains an effective way to eliminate double taxation and taxation not in accordance with a treaty. The 2022 data covers almost all MAP cases worldwide. Separate statistics are provided for transfer pricing cases and "other" cases (i.e., non-transfer pricing cases) for 2022 on the:

• Opening and ending inventory of MAP cases
• Number of new MAP cases started, completed, closed or withdrawn
• Average cycle time for MAP cases completed, closed or withdrawn

In the latest episode of the EY Transfer Pricing Roundup, EY US Tax Principal Jonathan Thompson hosts a detailed discussion with EY US Transfer Pricing Partner and Transfer Pricing Controversy Leader, Ryan Kelly, about the 2022 statistics and what taxpayers should be thinking about.

Access the 2022 OECD MAP Statistics here: https://www.oecd.org/tax/dispute/mutual-agreement-procedure-statistics.htm

Access and download the EY Tax Alert here: https://globaltaxnews.ey.com/news/2023-1960-oecds-2022-mutual-agreement-procedure-statistics-show-us-decreasing-map-case-inventories-increasing-time-to-close#:~:text=MAP%20statistics%20for%20all%20countries,and%202019%20(%2B3.5%25).