OECD: “Tax Certainty Day” highlights MAP and APA statistics

The OECD Forum on Tax Administration (FTA) held its annual tax certainty day on October 31, 2025. This was the seventh annual event that coincides with the release of the 2024 Mutual Agreement Procedure (MAP) statistics and the 2024 Advance Pricing Agreement (APA) statistics.

The day was based around a series of panels covering:

• MAP and APA statistics and awards (think the Oscars for tax administrations)

• Global MAP and APA practices

• Simplifications

• Practices that promote certainty, e.g., International Compliance Assurance Program (ICAP)

• Lower capacity countries

Key insights

The panels covered a wide range of issues, but some key themes include:

• Significant progress. The OECD, tax administrations, and businesses highlighted and recognized that there have been significant improvements to global MAP practices in the past 10 years. This view is borne out in the MAP statistics.

• Key performance indicators (KPIs). The OECD and tax administrations highlighted the value of the MAP and APA statistics as KPIs, both identifying when there are challenges and in supporting competent authorities (CAs) when they seek additional resources.

• Culture not products. There was a recognition that to deliver greater tax certainty, and increase dispute prevention, it is important that tax administrations adopt a collaborative not combative approach, which comes easier to some tax administrations than others.

• Multilateral MAPs and APAs. The FTA MAP Forum is proactively exploring how countries can pursue multilateral MAPs and APAs, when countries’ processes or legal systems can create obstacles.

• OECD best practices. Tax administrations take OECD best practice guidance, such as on APAs and MAPs, seriously and have incorporated it into their own domestic guidance.

• APAs for non-transfer pricing issues. Some tax administrations, notably Germany and Singapore, were exploring the use of APA-type processes for non-transfer pricing issues. It will be interesting to see whether APAs can be successfully applied outside transfer pricing, when issues may not present the same potential for jurisdictions to meet in the middle in a negotiation.

Highlights from the MAP and APA statistics

The MAP and APA statistics published by the OECD provide a lot of data that can help businesses access the effectiveness of countries' MAP / APA programs overall, but also in respect of specific bilateral relationships.

Some of the highlights from those statistics include:

• The transfer pricing MAP case inventory increased slightly in 2024, from 2,782 to 2,980. Case turnover is high, 1,119 cases were concluded in 2024, 40% of the opening inventory. APA inventories also rose slightly in 2024.

• While overall MAP inventories rose slightly, patterns vary by country. Some, like Spain, have more MAP cases than ever before; others, like India, have made significant steps towards reducing inventory.

• Japan continues to lead the rest of the world in its ratios of APAs to MAP cases, closely followed by other Asia Pacific jurisdictions: Australia, China, Korea, Malaysia, Singapore, Thailand, and Vietnam.

• Tax administrations continued to focus on resolving older cases that predate the adoption of a common statistical reporting framework in 2016, with mixed results. The United States significantly reduced its inventory and has only a dozen pre-2016 cases remaining, but 26 of the US non-transfer pricing cases dating from that period were closed without agreement.

Read the related OECD release (October 31, 2025), as well as a preliminary version of the 2025 update of the Consolidated Information on Mutual Agreement Procedures, which the OECD also released today.

KPMG observation

Further analysis will be important to better understand countries where the MAP or APA programs may be struggling or to identify relationships that are proving more difficult, as this was not covered in the OECD’s presentation.