World tax authorities resolve record number of international disputes

World tax authorities resolved a record 2,971 international tax disputes in 2025 using the Mutual Agreement Procedure (MAP).

This figure represents a 17.6% increase over the previous year, according to data published by the Organisation for Economic Co-operation and Development (OECD) during Tax Certainty Day. The average time to close these cross-border disputes dropped by 6.2% to 25.66 months. Authorities specifically improved the handling of cases not related to transfer pricing, which fell below the 24-month standardized target.

This administrative shift helped reduce the global inventory of pending MAP cases to 6,113 by the end of the year. While transfer pricing disputes remained slightly more complex with a 2.1% increase in their final inventory, the pace of new disputes slowed and closing times improved. Tax authorities also cleared a significant portion of older backlog, reducing cases from before 2016 by 41%.

These older cases now make up less than 4% of the remaining inventory, while 57% of open files are less than two years old. The OECD reported that 75.9% of analyzed cases resulted in a satisfactory solution for the taxpayer. To prevent future litigation, companies and tax offices increased the use of bilateral Advance Pricing Agreements (APA) by 11.6% in 2025. These agreements allow group subsidiaries to pre-negotiate tax treatments for operations.

Although the average processing time for these pacts remains long at 40.19 months, the OECD noted that the growth in these agreements shows corporate interest in protecting balances against unexpected tax risks.