OECD Mutual Agreement Procedure Statistics 2022

The OECD has released information and statistics on Mutual Agreement Procedures (“MAP”) statistics for 2022, covering 133 jurisdictions and practically all MAP cases worldwide.

Global Jurisdictions MAP Key Trends

The 2022 Global MAP Statistics show the following trends:

• Taxpayers are engaging with MAP more than ever – the number of new MAP cases opened in 2022 increased by 3% compared to 2021.

• The number of transfer pricing MAP cases resolved in 2022 remained at the same level as in 2021 with other cases down 6.5%, still representing a significant increase compared to 2020 (nearly +9%).

• Outcomes remain generally positive – approximately 73% of the MAPs concluded in 2022 fully resolved the issue both for transfer pricing and other cases.

• Average case times start to close in on the 24-month target – on average, MAP cases closed in 2022 took 25.3 months compared to 26 months in 2021.

Note: the agreed MAP Statistics Reporting Framework now makes a distinction between “transfer pricing”¹  cases and “other”² cases.

Ireland Transfer Pricing MAP Key Trends

• Ireland’s most significant MAP partners during 2021 were Denmark (3 remaining in inventory at end of 2021), Spain (15 in inventory), UK (7 in inventory), Italy (22 in inventory) and United States (10 in inventory). There were 25 cases closed with Denmark during the period and 11 cases with other treaty partners.

• There was positive news for Irish applicants, 100% of the 36 resolved MAP transfer pricing claims were concluded with full relief either bilaterally or by domestic means. 

• The average time to close MAP transfer pricing cases in Ireland in 2022 was approximately two years in length, down from three years in 2021. The length of time to finalise cases with Denmark and the UK was less than two years.

• Ireland closed more cases than it opened in 2022 and reduced its inventory of transfer pricing cases by eight to 77. 

• This year’s MAP Awards, which recognise the efforts of competent authorities, awarded Denmark and Ireland the award for the pair of jurisdictions which dealt most effectively with their joint caseloads for transfer pricing cases.

Further details on global jurisdictions and regional MAP statistics can be found on the OECD’s website here.

How EY can help:

EY has a team of transfer pricing experts that can assist clients in all phases of the MAP process, including:

• Provision of guidance on how best to utilise the MAP process,

• Preparation of the initial MAP request,

• Preparation of robust transfer pricing analyses and documentation in respect of the intra-group transactions in question,

• Assistance in negotiations and settlement with the relevant Competent Authorities.

If you wish to discuss MAP or require assistance with an on-going MAP process, please feel free to contact the EY team listed here or your regular EY contact.

Dan McSwiney
Partner, Transfer Pricing
+353 1 221 2094 | E: dan.mcswiney@ie.ey.com

Aoife Murray
Partner, Transfer Pricing
+353 1 479 2186 | E: aoife.murray1@ie.ey.com

Dominic McNeill
Director, Transfer Pricing
+353 1 221 1300| E: dominic.mcneill1@ie.ey.com

Tamas Adorjan
Director, Transfer Pricing
+353 1 478 6837 | E: tamas.adorjan@ie.ey.com