All material subject to strictly enforced copyright laws. © 2022 ITR is part of the Euromoney Institutional Investor PLC group.

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

This week Brazil’s former President Luiz Inacio Lula da Silva came out in support of uniting Brazil’s consumption taxes into one VAT regime, while the US Senate approved a corporate minimum tax rate.
The Dutch TP decree marks a turn in the Netherlands as the country aligns its tax policies with OECD standards over claims it is a tax haven.
Gorka Echevarria talks to reporter Siqalane Taho about how inflation, e-invoicing and technology are affecting the laser printing firm in a post-COVID world.
Tax directors have called on companies to better secure their data as they generate ever-increasing amounts of information due to greater government scrutiny.
Incoming amendments to the treaty could increase costs on non-resident Indian service providers.
Experts say the proposed minimum tax does not align with the OECD’s pillar two regime and risks other countries pulling out.
The Malawian government has targeted US gemstone miner Columbia Gem House, while Amgen has successfully consolidated two separate tax disputes with the Internal Revenue Service.
ITR's latest quarterly PDF is now live, leading on the rise of tax technology.
ITR is delighted to reveal all the shortlisted firms, teams, and practitioners for the 2022 Americas Tax Awards – winners to be announced on September 22
‘Care’ is the operative word as HMRC seeks to clamp down on transfer pricing breaches next year.
We use cookies to provide a personalized site experience.
By continuing to use & browse the site you agree to our Privacy Policy.
I agree