September 10, 2013
Toronto, Transfer Pricing
Montreal, International Corporate Tax
The total number of open Mutual Agreement Procedure (MAP) cases in OECD member countries for resolving cross-border tax disputes has increased to 4,061, a 6% increase from 2011, according to the OECD's latest annual report on MAP statistics for 2012. Canada's MAP inventory declined 1% during the same period. The report also notes that, for all reporting countries, the average time for the completion of MAP cases with other OECD countries decreased to about 23 months in 2012 (from 25 months in 2011 and 27 months in 2010). By comparison, Canada's average time to complete MAP cases was about 26 months, according to the latest reporting cycle.
As part of the OECD's work to improve the timeliness of processing and completing MAP cases under tax treaties and to enhance the transparency of the MAP process, the OECD releases annual statistics on the MAP caseloads of all its member countries and of partner economies that agree to provide such statistics.
The OECD report and tables, include statistics for each year of an OECD member country from 2006 through 2012 on areas including:
- MAP case opening and closing inventories
- Numbers of MAP cases initiated, completed, closed or withdrawn
- Average cycle times for cases completed, closed or withdrawn.
For more information, contact your KPMG adviser.
Information is current to September 10, 2013. The information contained in this publication is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavour to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act upon such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's National Tax Centre at 416.777.8500