OECD Released 2025 MAP Consolidated Report.

Introduction:

On October 2025, the OECD Released 2025 MAP Consolidated Report for 2025, providing a comprehensive assessment of how 141 jurisdictions manage cross-border tax disputes and prevent double taxation. The report, forming part of the OECD’s continuing implementation of the Base Erosion and Profit Shifting (BEPS) Action 14 Minimum Standard, confirms ongoing improvements in dispute resolution efficiency, with Switzerland and New Zealand ranking among the fastest and most effective jurisdictions worldwide.

Report Summary

The OECD’s 2025 MAP report consolidates statistical and procedural information relating to bilateral and multilateral dispute resolution mechanisms. Globally, the average time to resolve MAP cases remained steady at 27.4 months in 2024. Transfer pricing cases improved to 30.9 months, while other cases averaged 24.5 months. Case inventories experienced modest growth, with a 3.9 percent increase in transfer pricing cases and 2.7 percent in other disputes, indicating a return to pre-pandemic management patterns.

The report also highlights the continued growth of Advance Pricing Agreements (APAs) as proactive tools for dispute prevention. Eighty jurisdictions now authorise bilateral APAs, up from seventy-three in 2023, with forty-nine actively managing them. The number of bilateral APA applications increased by three percent in 2024, while the average completion time lengthened to 39.6 months. Despite this, the OECD underlines that bilateral and multilateral APAs are increasingly prioritised by tax administrations as key components of the international tax certainty framework.

Implications for Businesses

For multinational enterprises, the findings of the 2025 OECD MAP report reaffirm the critical importance of predictability and speed in resolving double taxation matters. While the global average remains above two years, jurisdictions such as Switzerland and New Zealand demonstrate that procedural efficiency and administrative clarity can substantially reduce resolution times.

Switzerland’s performance is largely attributable to the institutional organisation of its competent authority. The State Secretariat for International Finance (SIF) operates a dedicated MAP unit comprising seventeen professionals divided between attribution/allocation and other cases. The country’s 2023 guidance on the MAP process and its extensive treaty network ninety-nine treaties covering one hundred and ten jurisdictions facilitate uniform application and expedite resolution. The Swiss approach benefits from a strong legal infrastructure, streamlined internal coordination, and transparent procedural requirements.

New Zealand likewise distinguishes itself through its efficient handling of MAP cases. The Inland Revenue Department (IRD) manages its MAP programme through a compact team of specialists under clearly defined leadership. The Overall aim is to complete MAP cases within 12 months of receiving a request of assistance, the authority specifies that the cases will vary depending largely on the complexity of the matter in dispute.

The cooperation between Australia and New Zealand remains central to the stability of the regional tax framework. Their collaboration under the Closer Economic Relations agreement allows both countries to maintain consistent treaty practice, share administrative experience, and coordinate bilateral negotiations efficiently. This cooperation mitigates double taxation risks across trans-Tasman commerce, enhancing tax certainty and investor confidence within the Asia-Pacific region. It plain sucess

For businesses, these developments translate into tangible advantages: accelerated case resolution, reduced exposure to double taxation, and greater certainty in transfer pricing positions. However, the increasing complexity of APA negotiations and heightened documentation expectations require proactive compliance strategies and early engagement with tax authorities.

How MCORE Law can help?

MCORE LAW supports multinational groups and financial institutions in managing the challenges and opportunities arising from evolving tax certainty frameworks. The firm provides comprehensive advisory services covering dispute prevention, APA structuring, and MAP representation under OECD and bilateral standards.