On November 23, 2015, the OECD released the Mutual Agreement Procedure (« MAP ») program statistics for the 2014 reporting period.

• As part of the OECD’s work to improve the timeliness of processing and completing mutual agreement procedure (“MAP”) cases under tax treaties and to enhance the transparency of the MAP process, the OECD released, on November 23, 2015, their annual statistics on the MAP caseloads of all its member countries and of non-OECD economies that agree to provide such statistics for the year 2014.

• In 2014, the taxpayers facing double taxation issues introduced 2 266 new MAP cases in all OECD member countries, out of which 374 involving Germany, at the top of the list, followed by the USA (354), Belgium (205) and France (201). These four countries were therefore involved in half of the new cases of the year. China reported that it was involved in 29 new cases.

• Considered in the aggregate, MAP inventories in OECD member countries at the end of 2014 amounted to 5 423 unsettled cases, showing an increase of 18.77% compared to the preceding year. 1 029 involved Germany, at the top of this list also, followed by the USA (956), France (549) and Belgium (492). 55% of MAP unsettled cases involving OECD member countries therefore involved these four member states at the end of this year.

• For those countries that reported them, the average cycle times for cases completed, closed or withdrawn, increased slightly in 2014 (23.79 months) as compared to 2013 (23.57).

• Regarding France more specifically, 66 pending cases, out of 549, were with non-OECD countries at the end of 2014. The completion ratio much higher with other OECD member countries (47.5%) than with non-OECD economies (less than 7%). And the average cycle time for settlement reached 29 months, i.e. more than 5 months longer than the OECD average.

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