November 9, 2026
OECD Releases 2025 MAP and APA Dispute Resolution Statistics
Summary
On November 4, 2026, the Organisation for Economic Co-operation and Development (OECD) released its 2025 Mutual Agreement Procedure (MAP) and Advance Pricing Arrangement (APA) statistics, reporting the number of cross-border tax disputes resolved through MAP, the time required to resolve cases, and the use and processing of bilateral APAs across participating jurisdictions.
The statistics show that competent authorities resolved 2,971 MAP cases in 2025, representing a 17.6% increase from 2024. The average MAP resolution time decreased from 27.37 months to 25.66 months. For transfer pricing cases, however, the year-end MAP inventory increased by 2.1%. The number of bilateral APAs granted increased by 11.6% to 943, while the year-end APA inventory increased by 3.2% to 4,334 cases.
Key Points
1. MAP Cases Closed and Overall Inventory
The 2025 MAP statistics cover 137 jurisdictions participating in the OECD/G20 Inclusive Framework on BEPS. Competent authorities closed 2,971 MAP cases in 2025, an increase of 17.6% compared with 2024. The number of cases closed exceeded the growth in new cases, resulting in a 0.8% decrease in the year-end MAP inventory.
The overall MAP statistics were as follows:
Year-end MAP inventory in 2024: 6,161 cases
Year-end MAP inventory in 2025: 6,113 cases
MAP cases closed in 2025: 2,971 cases
Change in cases closed: +17.6%
Change in year-end inventory: -0.8%
The number of new MAP cases increased by 5.7% in 2025 compared with 2024.
2. Transfer Pricing and Non-Transfer Pricing MAP Cases
The OECD reported different developments in transfer pricing and non-transfer pricing MAP cases.
Transfer Pricing Cases
MAP cases closed increased by 6.0% to 1,187.
New MAP cases decreased by 2.4% to 1,236.
The year-end inventory increased by 2.1%, from 3,143 cases in 2024 to 3,209 cases in 2025.
Inventory growth slowed from the 3.9% increase recorded in 2024.
Transfer pricing cases accounted for more than half of the overall MAP inventory at the end of 2025.
Non-Transfer Pricing Cases
MAP cases closed increased by 26.7% to 1,784.
New MAP cases increased by 12.7%.
The year-end inventory decreased by 3.7%, from 3,018 cases in 2024 to 2,905 cases in 2025.
The reduction in the overall MAP inventory was primarily attributable to the decrease in non-transfer pricing cases.
3. MAP Resolution Times
The average time required to resolve MAP cases decreased in 2025.
Average MAP Resolution Time:
All MAP cases:
2024: 27.37 months
2025: 25.66 months
Transfer pricing cases:
2024: 30.90 months
2025: 30.29 months
Other cases:
2024: 24.52 months
2025: 22.58 months
The average resolution time for all MAP cases decreased by 6.2% compared with 2024. For non-transfer pricing cases, the average resolution time decreased by 7.9%, returning below the 24-month target after exceeding that threshold in 2024. For transfer pricing cases, the average resolution time decreased from 30.90 months to 30.29 months.
4. MAP Case Inventory Age
The OECD reported a reduction in longstanding MAP cases.
The number of cases received before January 1, 2016, or before January 1 of the year in which the relevant jurisdiction joined the Inclusive Framework, decreased from 406 at the beginning of 2025 to 240 at year-end, representing a reduction of approximately 41%.
These cases accounted for less than 4% of the overall MAP inventory at the end of 2025.
For cases received on or after January 1, 2016, or the applicable Inclusive Framework membership date, the age distribution at the end of 2025 was as follows:
Less than 2 years: 57.2%
Between 2 and 4 years: 24.1%
Between 4 and 6 years: 10.9%
More than 6 years: 7.8%
The proportion of open cases less than two years old was 55.9% in 2024, compared with 57.2% in 2025. Considering the overall inventory, including older cases, 44% of MAP cases remained open for more than two years at the end of 2025.
5. MAP Resolution Outcomes
The OECD also reported the outcomes of MAP cases resolved during 2025.
In 75.9% of reported outcomes, the issue raised by the taxpayer was fully resolved through a full agreement between competent authorities, unilateral relief, or a domestic remedy. The corresponding percentage was 83.5% for transfer pricing cases and 69.9% for non-transfer pricing cases. The reported outcomes were distributed as follows:
Full agreement between competent authorities: 63.4%
Unilateral relief and domestic remedies: 12.5%
Partial agreements: 2.3%
No agreement, including agreements to disagree: 4.1%
The 63.4% figure represents cases in which agreements fully eliminated double taxation or fully resolved taxation not in accordance with a tax treaty.
The 75.9% figure includes full agreements, unilateral relief, and domestic remedies. Accordingly, it represents a broader category of fully resolved taxpayer issues.
6. Bilateral APA Applications and Outcomes
The 2025 APA statistics reported the following aggregate figures:
Opening inventory: 4,285 cases
New applications: 1,168
APAs granted: 943
Applications rejected: 23
Cases closed for other reasons: 155
Closing inventory: 4,334 cases
Average time to grant an APA: 40.19 months
The number of bilateral APAs granted increased by 11.6% compared with 2024.
The number of rejected applications decreased from 56 in 2024 to 23 in 2025.
Despite the increase in APAs granted, the year-end APA inventory increased by 3.2%, from 4,199 cases in 2024 to 4,334 cases in 2025.
The number of new applications remained broadly stable at 1,168, while the average time required to grant an APA remained approximately 40 months.
Practical Considerations
The 2025 MAP and APA statistics show several developments compared with 2024.
1. Overall MAP inventory declined, while transfer pricing MAP inventory continued to increase.
Although the total MAP inventory decreased by 0.8%, the transfer pricing MAP inventory increased by 2.1%. New transfer pricing cases continued to exceed the number of cases closed, with 1,236 new cases compared with 1,187 closures. Transfer pricing cases also represented more than half of the overall MAP inventory at year-end.
2. MAP resolution times decreased, but transfer pricing cases continued to take longer to resolve.
The average resolution time for all MAP cases decreased from 27.37 months to 25.66 months. The average for transfer pricing cases remained at 30.29 months, compared with 22.58 months for other cases.
3. APA grants increased, while the APA inventory also expanded.
The number of bilateral APAs granted increased by 11.6% compared with 2024, and rejected applications decreased from 56 to 23. However, the year-end APA inventory increased by 3.2% to 4,334 cases, while the average processing time remained approximately 40 months.
These figures indicate that increased APA grants did not correspond to a reduction in the overall APA inventory during the reporting period.
Taken together, the statistics show a decrease in the overall MAP inventory and average MAP resolution time, alongside continued growth in transfer pricing MAP inventory and APA inventory.
Source:
Organisation for Economic Co-operation and Development (OECD), Tax certainty: OECD statistics show faster resolution of tax disputes and record MAP closures in 2025 (November 4, 2026)
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Disclaimer:
This content is for general informational purposes only and does not constitute professional advice.
Information provided herein is based on publicly available sources as of the publication date and may be subject to change.
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