The OECD's 2015 tax-treaty dispute resolution procedure statistics have been released.
The total number of open mutual agreement procedure (MAP) cases to resolve cross-border tax disputes in OECD member countries continued to increase in 2015, according to the OECD's latest annual report on MAP statistics for 2015. However, the average cycle times for cases completed, closed, or withdrawn decreased to 20.47 months in 2015 from 23.79 months in 2014. By comparison, Canada's target for resolving a case is 24 months.
Each year, the OECD releases annual statistics on the MAP caseloads of all its member countries and of non-OECD economies that agree to provide such statistics. This annual update is part of the OECD's work to improve the timeliness of processing and completing MAP cases under tax treaties and to enhance the transparency of the MAP process.
Improving the effectiveness of dispute resolution mechanisms was the primary objective of Action 14 of the BEPS Action Plan. One of the main outcomes of the work on Action 14 is the commitment by OECD and G20 countries to a minimum standard in terms of resolving treaty-related disputes. As part of this commitment, countries have agreed to report MAP statistics, which is expected to provide a tangible way to measure the effects of the implementation of the minimum standard.
As a result of the work done on BEPS Action 14, MAP statistics provided by the OECD for 2016 and onwards will contain new additional information, as well as reports from a significant group of non-OECD economies, most of which do not currently report MAP statistics to the OECD.
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Information is current to January 03, 2017. The information contained in this publication is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavour to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act upon such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's National Tax Centre at 416.777.8500