The latest OECD statistics show that Ireland is resolving transfer pricing double taxation disputes faster and taking less time to conclude advance pricing agreements (APAs). They offer a snapshot of that progress and the timelines taxpayers can expect.
Published on 4 November 2026 at the eighth annual OECD Tax Certainty Day, the 2025 statistics cover Mutual Agreement Procedures (MAPs) and APAs. The OECD also announced its Competent Authority Awards for 2025, which recognise the performance of Competent Authority Teams.
Ireland’s 2025 MAP and APA results
Ireland’s 2025 results show continued progress in resolving double taxation disputes and providing certainty for taxpayers. They follow recognition for the Irish Competent Authority in 2024, when Ireland won the most improved jurisdiction award in the APA category, and in 2023, when Ireland ranked second for the shortest average time to close non-transfer pricing MAP cases.
Ireland’s 2025 APA statistics and trends
- Ireland concluded 12 APAs in 2025, the highest annual total to date. The statistics also report three cases closed for other reasons and two applications rejected. The published statistics do not provide further detail on the reasons for rejection.
- 13 new cases were initiated in 2025, which is 10 fewer than in 2024. Overall, case closures outpaced new cases, reducing the Irish CA’s APA caseload from 80 to 76.
- Ireland’s average time to conclude APAs was 48.86 months, still longer than the global average but a marked improvement on the 2024 average of 52.58 months.
Ireland’s 2025 MAP statistics and trends
- Ireland closed 54 MAP cases in 2025, comprising 22 transfer pricing and 32 non-transfer pricing cases. During the year, 73 new cases were initiated, of which approximately 56% were transfer pricing cases.
- The total number of outstanding MAP cases rose from 171 to 190, an increase of approximately 11%. The net increase was driven by transfer pricing cases, which rose from 97 to 116.
- The average time to close transfer pricing MAPs fell from 35.57 months in 2024 to 28.29 months in 2025, an improvement of approximately seven months. Non-transfer pricing MAPs continued to close within 24 months on average, although the average closure time increased from 17.62 to 22.47 months.
- Ireland continues to resolve the vast majority of MAP cases by fully eliminating double tax. Double tax was fully eliminated in 95% of transfer pricing MAPs concluded in 2025, with 5% resulting in partial relief. Non-transfer pricing MAP outcomes were also strong, with 72% fully resolving taxation not in accordance with the treaty.
- Italy remained one of Ireland’s most significant MAP partners, accounting for approximately 39% of new transfer pricing cases and 27% of outstanding transfer pricing cases at year-end. Progress is being made in resolving cases between the two countries, with eight transfer pricing MAP cases concluded in 2025: seven resulted in full relief and one in partial relief. Ireland also has significant MAP inventories with Spain, the US and the UK.
The OECD’s full statistical report on Ireland can be found here.
Global MAP and APA trends in 2025
Globally, competent authorities closed a record 2,971 MAP cases in 2025, an increase of 17.6% on 2024. The average time to close a MAP case fell by 6.2% to 25.66 months in 2025, with non-transfer pricing MAP cases concluding within the 24-month target on average.
Overall, global year-end inventory declined by 0.8%, reversing the increase recorded in 2024 and returning broadly to 2023 levels. The statistics clearly demonstrate the increasing demand for APAs, with a 3.2% increase recorded in the inventory at the end of 2025 signifying that tax certainty remains a priority item for multinational taxpayers.
What the 2025 MAP and APA statistics mean for taxpayers
The 2025 statistics provide encouraging evidence of Ireland’s ability to deliver substantive relief in transfer pricing MAP cases, with stronger outcomes and shorter average closure times . However, the growing transfer pricing inventory and the age of a significant proportion of pending cases mean that taxpayers should continue to take a realistic view of the time required to secure certainty.
Similarly, the increase in APAs concluded and the shorter average completion time are welcome developments for Irish taxpayers. Taxpayers should continue to plan for a multi-year process, as there remains scope to reduce completion times.
Matheson’s transfer pricing team has extensive experience working on MAPs and APAs with our clients. Matheson regularly works with tax and legal advisors across a range of jurisdictions coordinating MAPs, APAs and international tax disputes.
Contact us
If you have any questions, please contact Anna Crowley or your usual Matheson Tax contact.
