OECD 2025 MAP and APA statistics: record closures, faster resolutions – but transfer pricing remains the bottleneck

Introduction

On 4 November 2026, at its Tax Certainty Day, the Organisation for Economic Co‑operation and Development (OECD) published its 2025 statistics on mutual agreement procedures (MAPs) and advance pricing arrangements (APAs). This is the third year of APA data reported under a common OECD framework, which means that taxpayers can now look at a genuine trend line rather than isolated snapshots.

In our alert last year, OECD’s MAP and APA statistics. What 2024 has changed for Multinational Enterprises, we highlighted stable but lengthy MAP timelines, a growing case inventory and a rising share of APAs closed without agreement. The 2025 figures show a markedly better picture on several of those fronts. Competent authorities closed more MAP cases than ever before, overall inventory fell, resolution times shortened and APA output rose by more than a tenth. Yet the improvement is uneven: transfer pricing (TP) disputes continue to accumulate, and the time needed to secure an APA has remained broadly stable at close to 40 months. Below we compare 2025 with 2024 and set out what this means in practice for multinational enterprises (MNEs).

MAP statistics: 2025 compared with 2024

Key takeaways:

• Record output turned the tide on inventory. Competent authorities closed 2,971 cases in 2025, the highest number on record. With closures outpacing the 5.7% rise in new cases, year‑end inventory fell by 0.8% to 6,113 cases, reversing the 2024 increase and returning broadly to end‑2023 levels.
• The improvement is driven by non‑TP cases. Non‑TP closures rose by 26.7% to 1,784, and that inventory fell by 3.7% despite a 12.7% rise in new cases. Their average resolution time dropped to 22.58 months, back below the 24‑month target after exceeding it for the first time in 2024.
• TP remains the bottleneck. TP closures rose by 6.0% to 1,187, but new TP cases (1,236) still exceeded them. The TP inventory therefore grew again, by 2.1% to 3,209 cases, and now makes up more than half of the total. At 30.29 months, the average TP case still takes roughly eight months longer than a non‑TP case. For MNEs, the practical message is that a TP dispute entering MAP today should still be budgeted at two and a half years or more.
• Legacy cases are being cleared. Cases predating 2016 fell by around 41%, from 406 to 240, and now represent less than 4% of inventory. However, 44% of the overall inventory had been open for more than two years at the end of 2025.
• MAP works when it concludes. In 75.9% of reported outcomes the taxpayer’s issue was fully resolved, rising to 83.5% for TP cases (69.9% for non‑TP). Only 4.1% of outcomes involved no agreement. MAP remains slow, but it is effective.

APA statistics: 2025 compared with 2024

Key takeaways:

• More APAs are being signed. Jurisdictions granted 943 APAs, 11.6% more than in 2024, and rejections fell sharply from 56 to 23. For taxpayers, that is an encouraging signal on both capacity and outcomes.
• Demand is holding firm. Applications remained broadly stable at 1,168. Even with higher output, applications continued to exceed APAs granted, and year‑end inventory rose by 3.2% to 4,334 cases.
• Timing has not improved. At 39.9 months, the average APA still takes well over three years. A five‑year APA filed today may already be in its fourth year when signed, which makes roll‑back requests and early renewal planning essential.

Key country trends

A view from our team

“The OECD’s latest statistics reflect encouraging progress in resolving international tax disputes, but also highlight the continuing challenges in achieving timely tax certainty. Success requires more than cooperation between tax administrations. Taxpayers and their advisers have an equally important role through constructive engagement, sound economic analysis, and a willingness to develop principled, workable solutions. Ultimately, lasting tax certainty depends on mutual trust, cooperation, and a shared commitment to the arm’s-length principle.” – John Wall, Partner

“The 2025 figures show APA programmes are more willing to engage, with more agreements granted and far fewer rejected. We're seeing that in practice: more groups want certainty before they act, particularly on high-value IP transfers, restructurings and recurring intra-group flows. For these transactions, tax certainty has become part of the value. Securing it upfront avoids complex, protracted audits years later, when the people and documents behind the deal may be long gone.” – Ravi Ahlawat, Tax Director

What MNEs should be doing now

• Price in time, not just tax. Build realistic MAP and APA timelines (around 30 months for TP MAP, 40 months for an APA) into cash‑tax forecasts, provisioning and uncertain tax position analysis, including interest and potential collection during pending procedures.
• Treat TP as the priority risk. With TP inventory still growing, focus dispute‑prevention resources on TP exposures such as intra‑group services, IP, financing and business restructurings.
• Use the APA window. Higher grant volumes and fewer rejections suggest programmes are more receptive. Well‑prepared applications for high‑value or recurring transactions are likely to see the strongest return.
• Benchmark your counterparties. Use jurisdiction‑level data to choose between unilateral, bilateral and multilateral routes, and to set realistic internal expectations for each treaty pair.
• Plan renewals early. With grant times close to 40 months, renewal applications and roll‑back requests should be prepared well before expiry.
• Join up your controversy toolkit. Align APAs, MAP, ICAP, domestic rulings and, within the EU, the Dispute Resolution Directive, so that each tool reinforces the others.

Conclusion

In our view, the 2025 statistics are the most encouraging set of results since the OECD began publishing them in their current form. Record MAP closures, falling overall inventory, shorter resolution times, a sharp reduction in legacy cases and more APAs granted all point to tax administrations investing seriously in tax certainty. However, the gains are concentrated outside transfer pricing. TP inventory continues to grow, TP cases still take around 30 months to resolve and APA timelines remain close to 40 months. For MNEs, the conclusion is clear: the system is improving, but those who plan early, choose the right instrument and prepare thoroughly will still secure certainty considerably faster than those who wait for a dispute to arise.

Please contact us if you would like to discuss how these developments affect your group.

For more information on APA and MAP processes, timelines and acceptance criteria by jurisdiction, please visit our APA & MAP Country Guide, which provides a jurisdiction‑by‑jurisdiction overview to help you assess and plan your dispute prevention and resolution strategy.