International Tax Review is part of the Delinian Group, Delinian Limited, 8 Bouverie Street, London, EC4Y 8AX, Registered in England & Wales, Company number 00954730
Copyright © Delinian Limited and its affiliated companies 2023

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 & bottom lb ros

More from across our site

Premier League football clubs are accused of avoiding paying up to £470 million in UK tax, while Malta is poised to overhaul its unique corporate tax system.
Bartosz Doroszuk of MDDP offers insights on Poland’s new tax legislation on shifted profits, as the implementation deadline looms nearer.
Four tax specialists preview the UK’s transfer pricing requirements, which come into effect on April 1.
The rise of the QDMTT will likely change how countries compete on tax and transfer pricing policy, but it may not reverse decades of falling corporate tax rates.
ITR’s latest quarterly PDF is going live today, leading on the EU’s BEFIT initiative and wider tax reforms in the bloc.
COVID-19 and an overworked HMRC may have created the ‘perfect storm’ for reduced prosecutions, according to tax professionals.
Participants in the consultation on the UN secretary-general’s report into international tax cooperation are divided – some believe UN-led structures are the way forward, while others want to improve existing ones. Ralph Cunningham reports.
The German government unveils plans to implement pillar two, while EY is reportedly still divided over ‘Project Everest’.
With the M&A market booming, ITR has partnered with correspondents from firms around the globe to provide a guide to the deal structures being employed and tax authorities' responses.
Xing Hu, partner at Hui Ye Law Firm in Shanghai, looks at the implications of the US Uyghur Forced Labor Protection Act for TP comparability analysis of China.