The Inclusive Framework on BEPS has agreed a new assessment methodology for Action 14 peer reviews which will be based around a jurisdiction’s mutual agreement procedure (MAP) experience:
Simplified peer review process: from January 2023, a simplified peer review will be used for jurisdictions which do not have ‘meaningful MAP experience’. This aims to help those jurisdictions set up a more robust programme for future MAP cases. The OECD has published a schedule for simplified peer reviews.
Full peer review process: from January 2024, full peer reviews will apply for jurisdictions which are considered to have ‘meaningful MAP experience’. The full peer review assessment schedule is expected to be published before the end of 2023
The Inclusive Framework has also agreed that jurisdictions should report the following additional data points in their annual MAP statistics (from the 2023 reporting year onwards):
a breakdown of the average time to close cases in the unilateral and bilateral stages of MAP; and
identification of the age of pending cases.
The OECD has also agreed the creation of a new annual framework for reporting advance pricing arrangement statistics which will be published on the OECD website from 2024 onwards.
The Inclusive Framework on BEPS has agreed a new assessment methodology for Action 14 peer reviews which will be based around a jurisdiction’s mutual agreement procedure (MAP) experience:
Simplified peer review process: from January 2023, a simplified peer review will be used for jurisdictions which do not have ‘meaningful MAP experience’. This aims to help those jurisdictions set up a more robust programme for future MAP cases. The OECD has published a schedule for simplified peer reviews.
Full peer review process: from January 2024, full peer reviews will apply for jurisdictions which are considered to have ‘meaningful MAP experience’. The full peer review assessment schedule is expected to be published before the end of 2023
The Inclusive Framework has also agreed that jurisdictions should report the following additional data points in their annual MAP statistics (from the 2023 reporting year onwards):
a breakdown of the average time to close cases in the unilateral and bilateral stages of MAP; and
identification of the age of pending cases.
The OECD has also agreed the creation of a new annual framework for reporting advance pricing arrangement statistics which will be published on the OECD website from 2024 onwards.
