Executive summary

On 31 October 2025, the OECD held its seventh annual OECD Tax Certainty Day bringing together a diverse group of stakeholders including tax authorities, business leaders, academics and policymakers to address the evolving landscape of tax certainty.

The event featured the release of the 2024 MAP and APA statistics, as well as the announcement of the annual MAP and APA awards. The latest statistics revealed a continued upward trend in MAP caseloads, alongside a notable increase in positive resolutions for taxpayers. The growing adoption of bilateral APAs emerged as a key theme, underscoring their expanding role in delivering greater predictability and confidence for multinational enterprises.

Guided by its G20 mandate, the OECD reaffirmed its commitment to simplifying tax rules and processes, while emphasizing that simplification must not compromise certainty, predictability or fairness. Discussions also highlighted the importance of digitalization and technology in advancing tax certainty, with stakeholders exploring collaborative approaches and innovative solutions to enhance dispute prevention and resolution.

Detailed discussion

Background

For the first time, the OECD held the Tax Certainty Day in hybrid format, with both in-person as well as online attendance. The meeting began with an opening speech by the OECD Secretariat and a representative of Business at the OECD (BIAC). The OECD Secretariat outlined the program for the day: the release of the 2024 MAP and APA statistics, the announcement of the MAP and APA Awards, as well as five panel sessions with representatives from Competent Authorities, tax authorities, the academic community and business. The key themes shaping the agenda included:

• Recognition of Tax Certainty as an essential tool for tax administration and business confidence
• Ongoing development around MAP and arbitration mechanisms to improve dispute resolution and enhance tax certainty
• The G20 priority and OECD focus on the simplification of tax systems to help ensure reliability and predictability, as well as strengthening dispute prevention and resolution processes to make them faster and more effective
• The International Compliance Assurance Programme (ICAP), multilateral MAP processes and Pillar Two as important developments in the global tax landscape
• Across all areas, the use of technology and digitalization as perceived enablers of more collaborative approaches, and innovation as a driver in dispute resolution

A representative of the Indian Revenue Service also presented a keynote address. Although India is not an OECD member, it is recognized as a key partner in the OECD's international tax initiatives. The keynote highlighted India's recent major Corporate Tax reform aimed at enhancing clarity, uniformity and taxpayer confidence. The speaker emphasized India's commitment to continue improving its now-robust APA and MAP programs.

2024 MAP and APA statistics

The OECD Secretariat released the 2024 MAP and APA statistics, which was followed by a discussion among stakeholders from the OECD, the Forum on Tax Administration (FTA) MAP Forum and actors from the business community.

Since 2016, the OECD has published annual MAP statistics as part of Base Erosion and Profit Shifting (BEPS) Action 14. Under Action 14, Inclusive Framework jurisdictions committed to a minimum standard to resolve treaty-related disputes in a timely, effective and efficient manner. This commitment includes annual reporting of MAP statistics to provide transparency around dispute resolution efforts and progress. For 2024, the MAP statistics included information for more than 140 jurisdictions. In addition, this is the second year in which the OECD also released APA statistics based on information for 49 jurisdictions with bilateral APA programs.

Key highlights in the 2024 statistics include the following.

The volume and inventory of new MAP cases increased to 2,731 new cases initiated in 2024 (compared to 2,336 in 2023), reversing the dip seen in 2023 and bringing the total MAP inventory to 6,147 cases at year-end. New transfer pricing cases increased by 29.1% (compared to 16% in 2023) and new other (non-transfer pricing) cases increased to 8.1% of cases (compared to 2.8% in 2023).

Closed MAP cases totaled 2,385 in 2024, showing a decline of 2.8% following a record high number of closures in 2023, driven by a 5.5% drop in closed transfer pricing cases. The OECD Secretariat described this as highlighting the continued importance of the broader tax-certainty agenda on simplification, dispute prevention and resolution.

The decline in closed cases resulted in a small increase in case inventory at the end of 2024, with transfer pricing cases up by 3.9% and other cases up by 2.7%. This signals a return to the trend line in inventory, particularly for transfer pricing cases, reversing the dip seen in 2023. The OECD Secretariat suggested this may have resulted from the impact of COVID-19 on adjustments that go to MAP.

In 2024, approximately 75% of total MAP cases were closed with full resolution for taxpayers (65.7% of agreements reached with full or partial elimination of double taxation,7.6% with unilateral relief and 4.9% resolved via domestic remedy). Negative outcomes remained rare (<5%), which the OECD Secretariat indicated demonstrates increased efficiency and confidence in the MAP process.

Timelines have remained stable with an average resolution time of 27.4 months in 2024 (from 27.3 in 2023) for all cases, with transfer pricing cases slightly improving to 30.9 months (from 32 months in 2023) and other cases increasing to 24.5 months in 2024 (from 23.4 in 2023). These timelines exceed the 24-month target under Action 14. However the OECD Secretariat suggested that new efforts in streamlining, standardization and additional resources will support driving down the time, especially for transfer pricing cases. Longer timelines are driven by complex transfer pricing cases and legacy issues, though only 3.4% of the MAP inventory at year end 2024 predated 2016 (against 13% in 2023). More than 56% of cases at the closure of 2024 were new from the last two years, reflecting ongoing efforts of the competent authority teams to resolve both legacy and recent disputes.

More than 100 jurisdictions reported active MAP activity, indicating a wider adoption and implementation of MAP globally. In 2024, the top 10 jurisdictions accounted for 72% of MAP cases started, while the top five represented 50% of active MAP cases. Jurisdictions such as Spain and the Netherlands saw the steepest increases in MAP inventories, driven by a surge in transfer pricing cases in Spain and other case types in the Netherlands. India stands out as having reduced MAP inventory, which the OECD Secretariat described as signaling effective case management and aligning with its recent extension of APA terms. Other major economies such as France, Germany, Italy and the United Kingdom remained relatively stable, indicating balanced inflows and closures.

For the second year in a row, the OECD also published the APA Statistics, which show uptakes in APA applications with 1,169 new APA requests filed in 2024, a 3% increase over 2023. A total of 826 APAs were granted in 2024, with only 57 cases rejected and 143 cases closed for other reasons. The inventory at year-end 2024 totaled 4,082 APAs (versus 3,972 in 2023).

In 2024, 80 jurisdictions reported allowing bilateral APAs, up from 73 in 2023, with 49 actively managing cases. Notably, jurisdictions continued to prioritize dispute prevention, with several reporting that APAs account for more than half of their bilateral transfer pricing caseload. Eleven jurisdictions achieved ratios of APA to transfer pricing MAP cases exceeding 50% for 2024, with Japan, Thailand and Vietnam in the top three, while the overall average ratio was 37.8%.

The time required to conclude APAs remained elevated, increasing to 39.6 months in 2024, up from 36.8 months in 2023.

A closer look at the data reveals that several jurisdictions have significantly improved the efficiency of their APA programs, achieving record levels of bilateral APA approvals and expanding into multilateral agreements. The OECD Secretariat highlighted the importance of these trends to promote the continued focus of the FTA MAP Forum on dispute prevention mechanisms and highlight the critical role of best practices outlined in the Bilateral APA Manual. The OECD Secretariat also highlighted the importance of the MAP Forum as a key platform for Competent Authorities to exchange best practices and improve efficiency, supporting the increase investment in resources and capacity building.

From the taxpayer's viewpoint, MAP is increasingly seen as a reliable safeguard against double taxation, particularly amid increasing audit activity, which contributed to a 30% increase in MAP cases. However, many disputes still center on simple transfer pricing issues, highlighting the need for simpler rules to reduce unnecessary reassessments. Greater taxpayer involvement in discussions could accelerate resolutions and enhance transparency, allowing administrations to focus on strategic matters rather than procedural disputes.

Panel 1: Taking stock of the tax-certainty journey

The first panel, consisting of representatives from tax authorities, ministries of finance, academia and business, reflected on the evolution and effectiveness of tax-certainty tools worldwide. The discussion highlighted that although global MAP inventories continue to rise, regional trends are highly diverse.

Europe's MAP inventory closely matches the global total, reflecting its significant share of cases. North America has seen a notable decline in transfer pricing cases, attributed to the adoption of standardized approaches and less case-by-case negotiation. In Asia-Pacific (APAC), MAP cases are decreasing despite economic growth, prompting questions about the efficiency of domestic remedies and the role of prevention. Africa and Latin America (LATAM) are experiencing increases in transfer pricing cases, with more countries now participating in MAP programs and reporting data, broadening the global sample. The Middle East North Africa (MENA) region has seen a recent uptick in MAP activity, though transfer pricing cases have declined, partly due to the introduction of corporate income tax regimes and the development of dispute resolution programs.

Main trends are:

• Regional disparities: Europe's MAP inventory is on par with the global total, while North America and APAC show declining or unexpectedly low case numbers relative to economic size. Africa and LATAM are expanding their MAP participation, and MENA is seeing new dynamics due to recent tax reforms.
• Variance in timelines and outcomes: Data shows significant differences in MAP timelines and outcomes across regions, with some jurisdictions achieving high success rates even with longer timelines.
• Shift toward prevention: Some regions, particularly in Asia, are moving away from MAP resolution to APA-based prevention.
• Best practice and collaboration: The importance of peer review, transparent data, and the application of best practices (such as those in the Bilateral APA Manual) was underscored, alongside the need for ongoing investment in competent authority resources.
• Taxpayer engagement: The panel stressed the value of stable, efficient, and well-designed systems, ongoing consultation with taxpayers, and pragmatic, transparent rulemaking. Greater taxpayer involvement in discussions was seen as key to accelerating resolutions and enhancing transparency.

Panel 2: Tax certainty through simplification

The second panel, consisting of representatives from tax authorities, academia and business, explored the critical relationship between simplicity and certainty in tax-rule design. The OECD's upcoming report to the G20 (expected to be released in mid-November 2025), "Enhancing Simplicity to Foster Tax Certainty and Growth," was highlighted as a foundation for ongoing consultation and future reforms.

Key considerations included:

• Balancing simplicity and detail: Speakers highlighted the ongoing challenge in designing tax rules that are simple enough to be easily understood and applied yet detailed enough to provide clear guidance and minimize ambiguity. Striking the right balance is essential to avoid rules that are either too complex or too open to interpretation. Yet any changes to tax rules should be evaluated for their cost versus the expected benefit.
• Reducing unnecessary complexity: Complexity often arises from redundant reporting requirements across jurisdictions, overlapping provisions, lack of clarity and guidance on data points. Key avenues mentioned as helpful to taxpayers and tax administrations in navigating complex issues and planning with confidence and trust included (1) streamlining and standardizing processes leveraging technology, clarity and stability of the regulatory environment and (2) eliminating duplication.
• Cross border safe harbor provisions: Speakers discussed the use of uniformized safe harbors as means to provide certainty for taxpayers, allowing them to operate within clear parameters while enabling tax authorities to allocate resources to more-complex or high-risk areas.

Panel 3: Tax administration practices to promote greater tax certainty

The third panel, consisting of representatives from tax authorities and business explored how tax administrations can foster greater certainty for taxpayers by moving beyond dispute resolution to proactive dispute prevention and early engagement.

Key considerations included:

• Early engagement and dialogue: Early and open communication between tax authorities and taxpayers was mentioned as essential. Providing timely guidance, standardized compliance requirements and clear documentation expectations helps prevent disputes before they arise.
• Tools for certainty: Administrations are using a range of tools, including safe harbors, advance rulings, audit guarantees and bilateral APAs, to provide upfront certainty and reduce the risk of future controversy. These tools are most effective when accompanied by transparency and a willingness to engage with taxpayers.
• Efficient resource allocation: Certainty allows tax authorities to focus resources on higher-risk areas, reducing the burden of audits and disputes for both sides. Programs like ICAP and cooperative compliance were highlighted as valuable tools to streamline risk assessment and compliance management, though speakers recognized that some improvements in effectiveness (e.g., for outcome, perimeters of the review) would still be required.
• Benefits for taxpayers and tax administrations: Early certainty supports business planning, resource allocation and investment decisions, while also enhancing voluntary compliance and improving tax collection. For administrations, early certainty leads to more efficient operations and a stronger reputation for fairness and reliability. The combination of the two supports investments and economic growth.
• Challenges and opportunities: While progress has been made, challenges remain in achieving global recognition for cooperative compliance programs such as ICAP, streamlining processes and integrating dispute prevention and resolution tools. The panel emphasized the importance of innovation, standardization and building trust through transparency and consistent engagement.

Panel 4: Global perspectives on MAP and APAs

The fourth panel, consisting of representatives from the FTA MAP Forum, tax authorities and business examined the evolving landscape of MAP and APA across jurisdictions, highlighting both progress and ongoing challenges in delivering tax certainty globally.

Key themes and insights included:

• Expanding participation and capacity building: More countries are joining MAP and APA programs, with peer review and knowledge sharing helping new entrants build effective teams and processes. The publication of the MAP and APA guidance at the OECD level, trainings and sharing of best practices of the FTA MAP Forum and the establishment of dedicated teams in numerous countries have led to increased case volumes and improved outcomes, as seen in recent developments in countries like Chile.
• Standardization and best practices: The adoption of international standards for statistical reporting and peer review has improved timelines and consistency. Arbitration provisions under the MLI, along with minimum standards and best practices, are supporting the resolution of complex cases and fostering greater trust in the system from taxpayers.
• Access and process clarity: Businesses value standardized and transparent processes, which create psychological safety and facilitate easier access to MAP and APA mechanisms. However, fragmented procedures and ambiguity between domestic and international guidelines remain challenges.
• Resolution and implementation: While outcomes are generally positive, procedural issues — such as payment processes and the cascading of competent authority decisions — can create uncertainty. Early prefiling discussions and feedback loops between taxpayers and tax authorities are critical for efficient implementation and resolution.
• Evolution of APA programs: APA programs are evolving rapidly, mirroring the earlier development of MAP. Openness, trust and collaboration between taxpayers, advisors and competent authorities are essential for the continued success and expansion of these programs.

Panel 5: Building capacity at the start of the tax-certainty journey

The fifth panel, consisting of representatives from tax authorities, ministries of finance and business, discussed building capacity at the start of the tax-certainty journey and the unique challenges faced by jurisdictions with limited resources and experience in implementing tax-certainty tools such as MAP and APA.

Key considerations and strategies include:

• Capacity building and training: Building effective teams and systems is essential. Investment in training and knowledge sharing often supported by peer review and international forums helps jurisdictions develop the expertise needed to manage MAP and APA programs.
• Simplified processes and practical support: Participation in peer review and international initiatives can be costly and challenging for low-capacity jurisdictions. Streamlining processes and providing practical guidance are critical to help ensure meaningful involvement and valuable input.
• Trust and engagement: Establishing trust between competent authorities and taxpayers is vital. Proactive domestic outreach, such as seminars and open communication, encourages taxpayer engagement and helps build confidence in APA and MAP programs.
• Balanced dispute resolution: Early and structured dialogue, including prefiling discussions and clear expectations, helps prevent disputes before they arise. Mechanisms like ICAP and APA foster certainty, reduce costs and support investment and economic growth.
• Principles for effective bilateral APA programs: Taxpayers need to have confidence that bilateral APAs processes rest on four pillars: (1) independence, (2) binding, (3) supported by the right resources and expertise and (4) timely resolution.
• Guidance: The development of a tax-certainty handbook was identified as a valuable resource to support low-capacity jurisdictions in navigating the complexities of dispute prevention and resolution.

MAP and APA Awards

At the close of the meeting, the OECD Secretariat announced the 2024 MAP and APA awards, recognizing the efforts of Competent Authorities across a range of metrics in six categories:

1. Average time to close MAP cases

The winners for the shortest time to close MAP cases in 2024 are:

• Switzerland for transfer pricing cases (20 months)
• New Zealand for Other cases (3.5 months)

2. Age of inventory

Mexico is the winner with no outstanding MAP case received before 1 January 2016 in ending inventory.

3. Caseload management

The winners for the highest closing percentage of cases for 2024, taking into account case outcomes, are:

• Netherlands for large inventory (47%)
• Norway for medium inventory (59%)

4. Cooperation

The winners for the highest number of MAP cases fully resolved through agreement by a pair of jurisdictions as compared to their total MAP caseload for 2024 are:

• India and Japan for transfer pricing cases (80)
• Australia and New Zealand for other cases (113)

5. Most-improved jurisdiction

The winner for the greatest increase in number of cases closed with unilateral relief or full agreement (2024 vs. 2023), is the United States, with an increase of 40 cases closed.

6. APA Awards

The winner for the ratio of APA end inventory to transfer pricing MAP cases for 2024 is Denmark with 39%, followed by Singapore with 26% and Switzerland with 25%.

Implications

The annual Tax Certainty Day provides useful information regarding the work being done on tax certainty by the OECD and participating jurisdictions. The annual meeting highlights the ongoing work focused on further improving dispute prevention and dispute resolution mechanisms. This year's meeting was the first one held in a hybrid format, with several panel sessions on topics related to tax certainty and simplification.

The 2024 MAP and APA statistics show that both MAPs and APAs continue to be on the rise. Nonetheless, there are significant variations on a regional and jurisdictional level. There is a growing focus on dispute prevention through APAs, including bilateral APAs. Further, work is being done on non-transfer pricing APAs, including bilateral APAs.

The international tax community is placing greater emphasis on early engagement, cooperative compliance, and the simplification of tax rules. By leveraging the full range of certainty tools, stakeholders are working to reduce disputes, foster more effective collaboration between tax authorities and taxpayers, and support broader economic growth objectives.

It is important for companies to monitor developments in the jurisdictions that are relevant to them and to consider how these tools can best be deployed to forestall or resolve controversy.