Recent OECD Insights
By November 2024, OECD reported that transfer pricing MAP cases average 32 months to resolution OECD.
As of 2023, over 4,000 APAs are active globally, with an average of 36.8 months to close, typically bilateral cases OECD.
Country-Specific Observations
USA: IRS APMA program offers both unilateral and bilateral APAs; timelines are lengthy but provide certainty.
UK & Europe: HMRC and EU countries frequently engage in pre-filing APA discussions; increased preference for multilateral APAs.
UAE: Still building dispute resolution frameworks; APAs expected to grow rapidly.
Australia: ATO uses APAs proactively; guidance on financial transactions added.
South Africa: APA facility is underutilized; initiatives to streamline procedures are underway.
Best Practices for Taxpayers
Plan for the long haul: Expect 2–3 years in negotiation and resolution.
Push for multilateral APAs: Gain broader protection across countries.
Build audits around ex-ante documentation: Robust FAR and HTVI proof supports credible agreements.
