In any case, the average duration of the cycle (i.e. before 2016 or year of BEPS IF membership, including after 2016 or year of BEPS IF membership) increased from 22.5 months on average to 22.2 months on average – although the underlying cycle times increased between 2016 and 2017 for all types of cases entering this average. THE OECD`s work to promote tax security includes work to improve the timely processing and conclusion of tax treaty procedures (“POPs”) and to improve the transparency of the POP process. As part of this work, the OECD makes available to the public, via its website, annual statistics on the number of POPs cases in all its Member States and non-MEMBER economies in the OECD that agree to provide such statistics. Although interesting and useful, the statistics provided do not necessarily show whether the map process works effectively in a given jurisdiction. A relatively small number of POPs cases, combined with relatively high foreign direct investment in or out of jurisdiction (and/or a well-equipped audit function in the field of cross-border taxation). For example, a small number of POPs cases may indeed be an indicator of tax management processes or dynamics that have resulted in cases not reaching POPs for one or more reasons. The table below shows the 2017 POP statistics for some legal systems. Some of these statistics are surprising – for example, the 98 cases closed in India, 95 are transfer prices. Countries such as the United States, Italy and Spain are also showing that they are effective in closing transfer prices. On the other hand, countries such as the Netherlands, the United Kingdom and Luxembourg have more effectively concluded transfer pricing deals. 4.
POP inventory statistics contain only cases of POPs that began after 2015. The agreed framework includes follow-up statistics for cases received before 1 January 2016 or the year of membership of BEPS IF, as well as for cases received on 1 January 2016 or the year of membership of BEPS IF. The main highlights of these map statistics compared to 2017 are listed below. For 1% of the POPs files closed, the parties agreed that there was no tax contrary to the tax treaty. Of the 26% of closed cases that did not solve the problem, 6% were withdrawn by taxpayers, while 20% were not resolved for various reasons (notably because there was no agreement between the competent authorities). Table 1 – EU POP statistics for the period up to December 2017 10/10/2018 – Improving the effectiveness and timeliness of dispute resolution mechanisms is the objective of Action 14 of the BEPS Action Plan (see the final report on action 14 of ACTION BEPS PLAN) and is also part of the broader G20/OECD tax security agenda.