Transfer pricing MAP cases on the rise: OECD

According to the statistics, transfer pricing cases continue to take more time with average time being approximately 33 months (30 months in 2017).

Transfer pricing disputes continue to increase, according to latest OECD statistics noting performance of over 85 tax jurisdictions in resolving tax treaty disputes through the mutual agreement procedure (MAP) framework.

According to the statistics, new transfer pricing cases are up by almost 20 percent, compared to 2017.

On average, transfer pricing cases continue to take more time with average time being approximately 33 months (30 months in 2017).

More than 80 percent of MAPs concluded in 2018 resolved the issue for transfer pricing cases, the statistics reveal.

Almost 75 percent of transfer pricing MAP cases closed were resolved with an agreement fully or partially resolving taxation not in accordance with tax treaty, five percent of them were granted a unilateral relief, and five percent were resolved via domestic remedy.

The 2018 MAP statistics were released at the first OECD Tax Certainty Day, which took place at OECD headquarters in Paris on September 16, 2019.