On October 31, 2025, the Organisation for Economic Co-operation and Development (OECD) released Mutual Agreement Procedure (MAP) statistics showing the US MAP program's open inventory of cases decreased modestly for transfer pricing cases but increased for non-transfer pricing cases in 2024. The US MAP program closed 290 total cases (up from 245 in 2023) and opened 329 (up from 247 in 2023).

The 2024 statistics were released at the OECD's seventh Tax Certainty Day.¹ During the event, the OECD announced the 2024 MAP and APA awards .

The 2024 MAP statistics include information from 141 members of the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (Inclusive Framework), including the United States. The 2024 data cover almost all MAP cases worldwide. Separate statistics are provided for transfer pricing cases and "other" cases (such as withholding, residency, permanent establishment and limitations on benefits) for 2024, including the following data points:

• Opening and ending inventory of MAP cases
• Number of new MAP cases started, completed, closed or withdrawn
• Average cycle time for MAP cases completed, closed or withdrawn

The 2024 MAP statistics also include the number of MAP cases that each jurisdiction has with each of its treaty partners. Moreover, a reporting jurisdiction's performance on key indicators can be compared with the other jurisdictions through the OECD's interactive tool .

2024 MAP statistics

The MAP statistics distinguish between transfer pricing cases and "other" cases. A transfer pricing MAP case relates to either attribution of profits to a permanent establishment or determining profits between associated enterprises. Any MAP case that is not a transfer pricing MAP case is characterized as an "other" MAP case. In the MAP statistics reporting, cases received before January 1, 2016, are distinguished from cases received on or after that date. For the jurisdictions that joined the Inclusive Framework after December 31, 2016, the MAP statistics distinguish between cases received before January 1 of the year the jurisdiction joined the Inclusive Framework and cases received on or after that date.

The interactive tool allows users to compare a specific jurisdiction's performance in 2024 for both types of cases. The comparison is based on seven key indicators:

• Starting inventory
• Cases started
• Cases closed
• Ending inventory
• Time from start to close (in months)
• Closing ratio
• Portion of pre-2016 (or pre-Inclusive Framework membership) cases in ending inventory

Users may customize their search by filtering among the indicators and selecting groups of jurisdictions.

The US MAP Program²

A comparison of some key points regarding the US MAP program for 2024 versus 2023 is provided below.

Table 1 Cases Closed: 2023 — 2024 Comparison

Table 2 Cases Opened: 2023 — 2024 Comparison

Table 3 MAP Inventory: 2023 — 2024 Comparison

In 2024, the IRS took an average of 39.6 months (up from 28.5 in 2023) to close transfer pricing cases opened after January 1, 2016, while other cases took an average of 23.3 months in 2024 (down from 25.3 in 2023) from beginning to end. Although the United States total MAP inventory once again rose in 2024, the number of cases opened and closed shows that the US MAP program continues to be strong. The time it took to close a case in 2024 was about eleven months longer for transfer pricing cases than in 2023; the time it took to close other cases remained stable between 2023 and 2024. While the statistics show that the United States continues to deal with cases from start to end in about three years, the statistics do not reflect how challenges like decreases in IRS personnel or the US government shut down may impact the timeline for taxpayers filing a MAP in 2025 or 2026.

MAP statistics for all countries

• Looking at the statistics in aggregate, approximately the same number of MAP cases were closed in 2023 and 2024. However, the number of open cases in the global inventory increased by 7% due to a 17% increase in the number of cases started in 2024 compared to 2023.
• The statistics show that MAP continues to be effective. As in 2023, approximately three-quarters of both transfer pricing and other cases concluded in 2024 with their issues fully resolved through an agreement to eliminate double taxation, the grant of unilateral relief or resolution through a domestic remedy. Just as in 2023, approximately 4% of MAP cases were closed with no agreement in 2024.
• On average, the MAP cases closed in 2024 took 30.9 months for transfer pricing cases (an improvement from 32 months in 2023) and approximately 24.5 months for all cases (compared to 23.4 months in 2023). The average time to close all types of cases was 27.4 months, which is above the OECD's recommended target of 24 months but remained relatively stable compared to 2023.
• For 2024, approximately 56% of open MAP cases are less than two years old and 24% are between two and four years old.

2024 APA statistics³

For the second year in a row, the OECD also published the advance pricing agreement (APA) statistics , which show an increase in global APA applications with 1,169 new APA requests filed in 2024 (a 3% increase compared to 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 was 4,199 APAs (compared to 4,082 at the start of 2024).

In 2024, 80 jurisdictions reported allowing bilateral APAs, up from 73 in 2023, with 49 actively managing cases. Notably, jurisdictions continue to prioritize dispute prevention by using APAs. Eleven jurisdictions achieved ratios of APA to transfer pricing MAP cases of over 50%,⁴ with Japan, Thailand and Vietnam in the top three. The United States is one of the countries with an APA to transfer pricing MAP ratio of over 50%. The overall average ratio for all reporting countries is 37.8%.

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

2024 MAP and APA awards

The OECD recognized the efforts of the following competent authorities:

• Switzerland, for the shortest time in closing MAP transfer pricing cases, and New Zealand, for the shortest time in closing other cases
• Mexico, for the smallest proportion of pre-2016 MAP cases in inventory
• Netherlands and Norway, for the most effective caseload management
• India and Japan, for transfer pricing cases, and Austria and New Zealand, for other cases, as the pairs of jurisdictions that dealt the most effectively with their joint caseload
• United States, for the most improved jurisdiction, which closed an additional 40 cases with positive outcomes in 2024 compared to 2023, with increases for both transfer pricing and other cases
• Ireland, for the greatest increase in APA cases granted in 2024
• Denmark, for the most effective APA caseload management in 2024

Implications

The 2024 statistics highlight that MAP remains an effective avenue for resolving double taxation, with more than three-quarters of cases concluded through agreement or relief. At the same time, the data reflect a dynamic environment for competent authorities globally, with an overall increase in both the number of new MAP cases and average resolution times. For the United States, the average cycle time for transfer pricing cases rose to just under 40 months, reflecting continued complexity in cross-border matters and sustained demand for MAP assistance.

Taxpayers should view these results as a signal that MAP continues to function well as a dispute resolution tool but may require longer lead times to reach completion. Early engagement and proactive coordination with treaty partners can help manage timelines and expectations.

The OECD's 2024 statistics also show that the number of bilateral APAs and jurisdictions offering them continues to grow, even as average approval times lengthened modestly to about 39.6 months. Taxpayers may wish to consider how the strategic use of both MAP and APA programs — one retrospective, one prospective — can support a broader approach to achieving tax certainty in an increasingly complex global environment.

Lastly, it is yet to be seen how the decrease in IRS personnel and the ongoing US government shutdown may impact the time it takes to close MAP (and APA) cases. Once the IRS reopens and begins meeting with treaty partners again, taxpayers and tax advisors will have a better idea of the impact.