OECD Releases MAP and APA Statistics for 2024

On 31 October, the OECD released the 2024 Mutual Agreement Procedure (“MAP”) and Advanced Pricing Agreements (“APA”) statistics, including for Ireland. 

This data is helpful to understand the extent to which Irish taxpayers are using relevant mechanisms to relieve or avoid double taxation and the efficiency of such processes. The figures show the continued increase in MAPs and APAs, increased timelines to conclude such processes and the importance of continued resourcing of the Irish competent authority function.

Overview of Irish MAP and APA Statistics

Mutual Agreement Procedures

• Ireland’s inventory of transfer pricing MAP cases grew to 97 cases in 2024 (up from 91 in 2023), with 31 new cases initiated against only 25 cases closed. 
• 60% of closed TP MAP cases in 2024 achieved a full elimination of double taxation through Competent Authority Agreement.
• Based on closing inventory at the end of 2024, Ireland’s most significant MAP partners were Italy (23 cases), Spain (17 cases), the United Kingdom (16 cases) and the United States (11 cases).
• The average time to close a transfer pricing MAP involving Ireland increased to 35.57 months in 2024 (up from 31.50 months in 2023 and above the OECD average of 30.9 months (and the OECD’s). 

Advanced Pricing Agreements

• Ireland’s inventory of APA applications increased from 68 to 80 in 2024 (23 APA requests received in 2024, 10 granted and 1 case closed for other reasons). This compares to only 1 APA agreed in 2023 and meant Ireland won the new APA award for “most improved jurisdiction”!
• The average time to grant an APA also fell significantly (by 19 months) to 52.58 months in 2024 (but down from 71.97 months in 2023). Despite the improvement, the average time to conclude an APA remains above the global APA average of 39.6 months. 

If you have any questions, please reach out to our transfer pricing team today.