Episode 26: Navigating Transfer Pricing and Dispute Resolution: Insights from the 2022 Mutual Agreement Procedure Statistics

Episode 26: Navigating Transfer Pricing and Dispute Resolution: Insights from the 2022 Mutual Agreement Procedure Statistics

Statistics from Organisation for Economic Co-operation and Development (OECD) on Mutual Agreement Procedures (MAP) for 2022 show that increase in global tax disputes and a more accessible MAP process resulting in more taxpayers seeking relief. The 2022 statistics demonstrate that MAP remains an effective way to eliminate double taxation and taxation not in accordance with a treaty. The 2022 data covers almost all MAP cases worldwide. Separate statistics are provided for transfer pricing cases and "other" cases (i.e., non-transfer pricing cases) for 2022 on the:

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  • Number of new MAP cases started, completed, closed or withdrawn
  • Average cycle time for MAP cases completed, closed or withdrawn

In the latest episode of the EY Transfer Pricing Roundup, EY US Tax Principal Jonathan Thompson hosts a detailed discussion with EY US Transfer Pricing Partner and Transfer Pricing Controversy Leader, Ryan Kelly, about the 2022 statistics and what taxpayers should be thinking about.

Access the 2022 OECD MAP Statistics here: https://www.oecd.org/tax/dispute/mutual-agreement-procedure-statistics.htm

Access and download the EY Tax Alert here: https://globaltaxnews.ey.com/news/2023-1960-oecds-2022-mutual-agreement-procedure-statistics-show-us-decreasing-map-case-inventories-increasing-time-to-close#:~:text=MAP%20statistics%20for%20all%20countries,and%202019%20(%2B3.5%25).

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Avsnitt(73)

Episode 73: Brazil's New Transfer Pricing Landscape: Implementation and Documentation

Episode 73: Brazil's New Transfer Pricing Landscape: Implementation and Documentation

In this special edition of EY Transfer Pricing Roundup, recorded in São Paulo, host Jonathan Thompson is joined by Daniel Biagioni, Milton Gonzalez Malla, Charikleia Tsoukia, Sandra Knaepen and Gustav...

23 Sep 13min

Episode 72: Perrigo v. United States: Court Rejects Government's Blanket Assertion of Lack of Economic Substance and Hindsight in Transfer Pricing

Episode 72: Perrigo v. United States: Court Rejects Government's Blanket Assertion of Lack of Economic Substance and Hindsight in Transfer Pricing

In this episode of EY Transfer Pricing Roundup, host Ryan J. Kelly is joined by Kent Stackhouse to unpack Perrigo Company v. United States (W.D. Mich.). They discuss the 2006 contract reassignment at ...

12 Sep 7min

Episode 71: Tax Controversy in France: Insights for Multinational Businesses

Episode 71: Tax Controversy in France: Insights for Multinational Businesses

In the latest episode of the EY Transfer Pricing Roundup, EY host and Financial Services Transfer Pricing Leader Jonathan Thompson is joined by EY France Transfer Pricing Leader, Nadia Sabin and EY EM...

17 Aug 16min

Episode 70: Understanding the OECD Consultation on Intra-Group Services: Insights and more from the OECD

Episode 70: Understanding the OECD Consultation on Intra-Group Services: Insights and more from the OECD

In this episode of the EY Transfer Pricing Roundup, EY host and Financial Services Transfer Pricing Leader, Jonathan Thompson is joined by Manuel de los Santos Poveda, Head of the OECD Transfer Pricin...

16 Juli 45min

Episode 69: UK Transfer Pricing Update: HMRC Statistics and Enforcement Trends

Episode 69: UK Transfer Pricing Update: HMRC Statistics and Enforcement Trends

UK transfer pricing continues to evolve at a rapid pace. Recently we have seen the release of the Guidelines for Compliance, the outcomes of a number of transfer pricing cases and, a transfer pricing ...

15 Juli 11min

Episode 68: IRAS Transfer Pricing Update – Version 8.0

Episode 68: IRAS Transfer Pricing Update – Version 8.0

The most recent version of the Singapore Transfer Pricing Guidelines, version 8, was published late last year. EY Host and Financial Services Transfer Pricing Leader, Jonathan Thompson recently sat do...

9 Juni 13min

Episode 67: Brazil Transfer Pricing Update: Insights from the first year of Arm's Length Transfer Pricing

Episode 67: Brazil Transfer Pricing Update: Insights from the first year of Arm's Length Transfer Pricing

Brazil fundamentally re‑engineered its transfer pricing framework, moving away from its long‑standing formulaic approach and aligning with the #OECD arm's length principle. In this episode, EY host an...

1 Maj 11min

Episode 66: Navigating Canada's Transformative Transfer Pricing Reforms

Episode 66: Navigating Canada's Transformative Transfer Pricing Reforms

Canada is entering a new era of transfer pricing regulation. With the federal government introducing sweeping amendments through the 2025 budget and Bill C‑15, businesses now face a far more substance...

9 Feb 29min

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