Thu, Oct 10, 2019
In October 2015, the Organization for Economic Cooperation and Development (OECD) finalized its report titled Action 14: Making Dispute Resolution Mechanisms More Effective. As part of Action 14, the members of the Inclusive Framework on BEPS (IF)4 committed to implement a minimum standard to ensure that treaty-related disputes were resolved in a timely, effective, and efficient manner. Mutual Agreement Procedures (MAP) offer an important process for purposes of resolving double tax disputes arising from international tax matters – many of which will relate to transfer pricing. Through MAPs, the relevant taxing authorities (operating under the provisions of tax treaties between the countries involved) are supposed to arrive at a joint agreement regarding the allocation of profits between tax jurisdictions.
Now in its second full year of implementation, the OECD released updated MAP statistics for 2018 on September 16, 2019. Consistent with its 2017 statistics reporting, the updated 2018 MAP Statistics Reporting Framework makes a distinction between the cases received before Action 14 (i.e., before January 1, 2016 or January 1 of the year of joining the BEPS inclusive framework) and after Action 14 implementation (i.e., cases received on or after January 1, 2016 or January 1 of the year of joining the BEPS inclusive framework).
The key takeaways from the 2018 MAP Statistics include the following:
Additional information concerning the Mutual Agreement Procedure Statistics for 2018, as well as comparisons of MAP statistics between jurisdictions, can be found on the OECD’s website here.5
Read Transfer Pricing Times – September 2019
Source:
4Members of the inclusive framework as of January 1, 2019 are listed here.
5Website: http://www.oecd.org/tax/dispute/mutual-agreement-procedure-statistics.htm
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