International · International tax development
OECD reports faster MAP resolution but bilateral APAs still take over three years
On 4 November 2026, the OECD released its 2025 MAP and APA statistics, showing quicker dispute resolution alongside a continuing multi-year wait for bilateral advance pricing arrangements.
- Official document:
- 2025 MAP and APA Statistics; release 4 November 2026
- Development date:
- 2026-11-04
Resolution and prevention differ
Competent authorities closed 2,971 mutual agreement procedure cases, up 17.6%. Average completion time fell to 25.66 months, and the closing inventory was 6,113. For transfer-pricing disputes, however, new cases still exceeded closures and inventory rose 2.1%. The aggregate improvement therefore does not mean every dispute category is shrinking.[1]
Planning implications
Bilateral APAs granted increased to 943, but average grant time remained 40.19 months. For MNE tax teams, the contrast is a planning signal: dispute prevention may require a longer lead time than the headline MAP average suggests. These are historical programme averages, not promised completion times for a particular application.[1]
No change to legal rights
The statistics sit within the BEPS Action 14 tax-certainty framework. This release does not amend domestic law or a treaty, create entitlement to relief, or replace the procedural rules governing an individual case. Groups should distinguish the data from the legal basis and deadlines of their own dispute or APA request.[1]
Official sources
- [1] Tax certainty: OECD 2025 MAP and APA statistics announcement
OECD · Document date: 2026-11-04
Announcement dated 4 November 2026; paragraphs on MAP closures, average duration and transfer-pricing inventory; bilateral APA grants and average grant time; Action 14 context. Full announcement body read through search/open after one direct-open error.