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At the sixth Tax Certainty Day, the OECD unveiled the winners of the 2023 MAP and APA Awards, celebrating jurisdictions that demonstrated excellence in resolving tax disputes through Mutual Agreement Procedure (MAP) and Advance Pricing Agreements (APA). 

For the first time, the APA statistics were included in the evaluation. The awards recognized jurisdictions for their efficiency, cooperation, and progress in managing cases under the OECD's Base Erosion and Profit Shifting (BEPS) Inclusive Framework. 

Below are the winners across six key categories.

CATEGORY 1: AVERAGE TIME TO CLOSE MAP CASES

Award 1: Transfer Pricing Cases
Winner: Netherlands
The Netherlands was recognized for closing transfer pricing cases in the shortest average time, at approximately 22 months. Jurisdictions considered for this award closed more than 50 transfer pricing cases in 2023.

Award 2: Other Cases
Winner: Australia
Australia emerged as the winner for resolving non-transfer pricing cases in the shortest time, with an average closure time of 7.3 months. Jurisdictions considered here closed more than 20 other cases in 2023.

CATEGORY 2: AGE OF INVENTORY

Award 3
Winner: Canada
Canada earned recognition for having the smallest proportion of cases in its inventory that were received before January 2016, with only 1.12% of cases in this category. Jurisdictions with more than 100 cases remaining in their 2023 end inventory were considered.

CATEGORY 3: CASELOAD MANAGEMENT

Award 4: Large Inventory
Winner: Netherlands
The Netherlands also won this category with a remarkable closing ratio of approximately 52%, reflecting efficient caseload management in jurisdictions with over 100 cases remaining at the end of 2023.

Award 5: Medium Inventory
Winner: Norway
Norway achieved a closing ratio of 54%, the highest among jurisdictions with between 20 and 100 cases left in inventory at the end of 2023, showcasing impressive caseload management.

CATEGORY 4: COOPERATION

Award 6: Transfer Pricing Cases
Winner: Canada and France
Canada and France took the top spot for their collaboration on transfer pricing cases, achieving an agreement score of 86 points. The score measures the number of cases fully resolved through agreement relative to the total MAP caseload.

Award 7: Other Cases
Winner: Austria and Switzerland
Austria and Switzerland won in the category of other cases, with an agreement score of 83 points, demonstrating their strong bilateral cooperation in resolving tax disputes.

CATEGORY 5: MOST IMPROVED JURISDICTION

Award 8
Winner: France
France was recognized for the greatest improvement in dispute resolution, with an increase of 212 cases closed with unilateral relief or full agreement in 2023 compared to 2022. This included a substantial rise of 137 cases in transfer pricing and 75 cases in other disputes.

CATEGORY 6: APA AWARD FOR FOCUS ON DISPUTE RESOLUTION

Winner: Japan
Japan was awarded for having the highest proportion of APA cases relative to its transfer pricing MAP caseload, with an impressive 84.7% of its transfer pricing cases being resolved through APAs in 2023.

These awards not only highlight the jurisdictions that have excelled in managing tax disputes but also underscore the importance of international cooperation and continuous improvement in the global tax landscape.

SOURCE/RECOMMENDED READ: 

• OECD Tax Certainty Day 2024 | OECD