OECD’s MAP and APA statistics. What 2024 has changed for Multinational Enterprises

Introduction

Last year, in our article “OECD’s 2023 MAP and APA Statistics: Key Insights for Multinational Enterprises”, we analysed the inaugural global statistics on Advance Pricing Arrangements (APAs) alongside the longstanding mutual agreement procedures (MAPs) data released by the Organisation for Economic Co‑operation and Development (OECD).

On 31 October 2025, as part of the 7th edition of its Tax Certainty Day, the OECD released the 2024 statistics on MAPs and APAs, providing a comprehensive overview of how jurisdictions are working on resolve cross-border tax disputes and prevent double taxation. 

This alert highlights evolving trends and sets out what multinational enterprises (MNEs) should be considering in response.

 

What’s new: MAP statistics update

• The OECD’s 2024 MAP data confirmed that resolution times remain broadly stable in 2024 at 27.4 months on average, with Transfer Pricing cases slightly improved at 30.9 months (down from 32 in 2023) and other cases at 24.5 months (up from 23.4 in 2023). This persistent time gap suggests that Transfer Pricing cases remain more complex and resource-intensive.
• The results also show a small increase in case inventory, with transfer pricing cases up by 3.9% and other cases by 2.7%.
• Emerging economies (e.g., Brazil and Indonesia) are increasingly active in MAP, reflecting growing cross-border tax engagement.
• It also provided fresh data on case-age: only 3.3% of cases predate 2016, fewer than 20% are older than four years, and over 56% are under two years, marking an improvement over 2023.

 

What’s new: APA statistics update

• According to the 2024 APA Statistics, 80 jurisdictions reported allowing bilateral APAs, up from 73 in 2023, with 49 actively managing cases.
• In 2024, the number of bilateral APAs rose by 3%, and roughly a quarter of the inventory was closed, consistent with 2023, demonstrating that MNEs continue to use APAs as a key proactive risk management tool.
• APAs granted were slightly down by 2%, while rejections or closures without agreement rose from 12% to over 19%.
• The average time to grant APAs increased to 39.6 months in 2024 (up from 36.8 months in 2023).

 

Key country trends: MAP and APA by jurisdiction

Below is an updated summary of how key jurisdictions are performing in the MAP/APA space.

Jurisdiction	MAP highlights	APA highlights
United Kingdom (UK)	The UK continues to resolve a substantial number of MAP cases and average closing time for TP MAP cases remains in the mid-20s months.	The UK’s APA programme remains well-established; the average of closing times was 53 months.
United States (US)	The US MAP programme closed ~254 cases in 2024 with an average of ~39.58 months for TP cases and ~23.31 months for other cases.	US APA median time was ~42.34 months in 2024.
Italy	Italy remains high-volume for MAP; average resolution times for TP MAPs was 27.87 months.	Italy’s APA programme had an average duration of 34.55 months.
Spain	Spain continues to perform in line with mid-range European jurisdictions: average MAP resolution time is ~30.75 months for TP cases.	Spain’s APA average time was 52 months in 2024.
Japan	Japan stands out for quicker MAP resolution in TP cases (~29.68 months).	Japan ranks high in APA adoption: the OECD recognised Japan for its “Focus on Dispute Prevention”, noting ~84.7% of its TP disputes were APAs rather than MAPs.
Germany	Germany continues its strong MAP performance: ~23.85 months average closing time for TP MAP cases.	Germany remains active in APAs, with closing times of 54.10 months in 2024.

Strategic action points for MNEs

• MAP as a safety net: The long duration of MAP cases reinforces that MAP is not a quick fix, and highlights the need for early engagement with tax authorities to avoid disputes in the first place.
• Global coordination: Develop integrated tax-governance frameworks where TP, MAP/APA strategy, customs/tariff exposure and indirect tax considerations are aligned.
• APA-first mindset: Consider APAs not just for high-risk jurisdictions, but also for key value drivers (e.g., IP or procurement hubs) in order to lock-in certainty.
• Jurisdiction-specific tracking: Maintain dashboards of key jurisdictions (closing times, inventories, age-profiling) – different jurisdictions continue to perform at widely varying levels.
• Supply-chain and commercial triggers: Don’t wait for a dispute. Integrate MAP/APA risk-screening into commercial structuring (e.g., new intangibles, cost-sharing, business-model shifts) so you can act early.

 

Conclusion

The OECD’s updated MAP and APA statistics reflect both progress and persistent complexity. The global reduction in MAP inventory and increasing closure volumes signal improved tax-administration capacity. The rising prominence of APAs – and in some jurisdictions the falling completion times – mark a shift toward preventive tax certainty rather than reactive dispute resolution.

Yet resolution timelines remain long, and jurisdictional performance remains uneven. For MNEs, navigating ambiguity is not optional – the ability to anticipate, structure, file and monitor MAP/APA exposure is now a key component of the tax-governance toolkit.

Please contact us if you would like to learn more, and for more information on APAs and MAPs processes and acceptance criteria by jurisdiction please visit our APA & MAP Country Guide.