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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

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