MAP becoming more popular in the UK

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

MAP becoming more popular in the UK

On September 2 2013, the OECD released its 2012 mutual agreement procedure (MAP) statistics of its member countries and of partner economies that agreed to provide such statistics.

The OECD’s purpose for publishing such data is to improve the timeliness of resolving cases of double taxation through MAP under tax treaties and to enhance the transparency of the MAP process.

The statistics show that at the end of the 2012 reporting period, the total number of open MAP cases reported by OECD member countries was 4,061, which represents an increase of 5.8% compared with the 2011 reporting period. The average time for completion of MAP cases with other OECD member countries was 23.20 months in the 2012, compared with 25.39 months in the 2011 reporting period.

The UK MAP caseload has increased steadily from 2006 (the earliest year recorded in the statistics) with 69 new cases initiated in the 2012 reporting period; up from 54 new cases in the 2011 reporting period. The UK had an inventory of 143 outstanding cases at the end of the 2012 reporting period compared with 133 in 2011.

Of the 69 new UK cases initiated in 2012, the majority (64 of them) were with other OECD countries with only five being with non-OECD countries.

Overall, the statistics show that taxpayers are increasingly looking for dispute resolution through the MAP procedure and that trend looks set to continue over the medium term as transfer pricing controversies are likely to rise as more countries focus tax enquiries in this area.

By UK correspondents to TPWeek, Grant Thornton

Elizabeth.hughes@uk.gt.com

Wendy.Nicholls@uk.gt.com



more across site & shared bottom lb ros

More from across our site

It should be easy for advisers to be transparent about costs, Brown Rudnick partner Matthew Sharp said in response to exclusive ITR in-house data
The sprawling legislation phases out Joe Biden-era green tax incentives for businesses; in other news, the UK will reportedly maintain its DST despite US pressure
New French legislation should create a more consistent legal environment for taxing gains from management packages, say Bruno Knadjian and Sylvain Piémont of Herbert Smith Freehills Kramer
The South Africa vs SC ruling may embolden the tax authority to take a more aggressive approach to TP assessments, an adviser tells ITR
Indirect tax professionals now rate compliance as a bigger obstacle than technology and automation; in other news, Italy approved a VAT cut on art sales
AI-powered tax agents are likely to be the next big development in tax technology, says Russell Gammon of Tax Systems
FTI Consulting’s EMEA head of employment tax and reward tells ITR about celebrating diversity in the profession, his love of musicals, and what makes tax cool
Canadian Prime Minister Mark Carney and US President Donald Trump have agreed that the countries will look to conclude a deal by July 21, 2025
The firm’s lack of transparency regarding its tax leaks scandal should see the ban extended beyond June 30, senators Deborah O’Neill and Barbara Pocock tell ITR
Despite posing significant administrative hurdles, digital services taxes remain ‘the best way forward’ for emerging economies, says Neil Kelley, COO of Ascoria
Gift this article