APA, MAP Stats, Canada’s New Proposal: Transfer Pricing Report

Hello and welcome to the Transfer Pricing Report. I’m Caleb Harshberger, and this week we’re looking at that OECD data dump on last year’s APA and MAP statistics.

Asking around about the report, I heard something repeated a few times: Tax authorities around the world are taking too much time to close MAP and APA cases, while companies increasingly seek their help to reach agreements that would avoid disputes or double taxation.

New MAP cases jumped a whopping 29% for transfer pricing cases in 2024, and bilateral APAs ticked up 3% last year, according to figures the OECD ...