On 31 October 2025, the OECD published its 2024 statistics on Mutual Agreement Procedures (“MAPs”) and Advance Pricing Agreements (“APAs”) as part of the OECD’s Tax Certainty Day. The OECD also handed out awards to Competent Authority teams that achieve strong results in resolving cases. These statistics and awards provide key insights on trends in MAPs and APAs involving Ireland.
APAs – Ireland wins most improved jurisdiction
For the first time, the OECD handed out awards to Competent Authorities that perform well in concluding APAs. The Irish Competent Authority team was awarded the ‘most improved jurisdiction’ in the APA category, which acknowledges the 900% increase in APAs granted to Irish taxpayers in 2024 (compared to 2023). This achievement acknowledges the significant efforts of the Irish Competent Authority team to provide Irish taxpayers with certainty on their transfer pricing arrangements since the formal introduction of Ireland’s APA programme almost 10 years ago and the rapid increase in the number of APAs being sought by taxpayers.
Key insights on Ireland – MAP and APA trends
- Ireland concluded a total of 10 APAs in 2024. This is a substantial increase from the conclusion of just one APA in 2023. The average timeframe to conclude an APA involving Ireland (more than 4 years) is reflective of the complex and novel issues that must be considered by the Competent Authorities and the protracted nature of negotiations between competent authorities more generally.
- During 2024, Ireland commenced 23 new APA cases. At the end of 2024, Ireland had a significant inventory of 80 open APA cases.
- In 2024, Ireland closed 68 MAP cases, 37% of which were transfer pricing related cases. 50% of new cases are transfer pricing MAP cases. At the end of 2024, Ireland had a total of 167 open MAP cases.
- Over 24% of Ireland’s transfer pricing MAP cases were with Italy, reflecting the increased level of transfer pricing audit activity in Italy, which is impacting Irish taxpayers. Most of the remainder of Ireland’s MAP cases are with Spain, the US, and the UK.
- Ireland continued to resolve the majority of its MAP cases by agreeing to fully eliminate double tax (60%). Interestingly, 20% of transfer pricing MAP cases were resolved by granting partial MAP relief. The majority of MAP cases where only partial relief was granted involved Italy, which is reflective of Italy’s recent tax audit focus on MNEs.
- The 2024 statistics show that there was an increase in the average time taken to resolve MAPs. The average time to close transfer pricing MAPs is approximately 3 years (up from 2.5 years in 2023). For non-transfer pricing cases, the average timeframe is less than two years (up from less than a year in 2023).
The OECD’s full statistical report on Ireland can be found here.
Irish Competent Authority Resources
- Given the increase in volume and complexity of international tax disputes, it is increasingly important that the Irish Competent Authority has a strong, well-resourced team to resolve cases effectively.
- The 2025 update of the OECD’s Consolidated Information on MAPs notes that Ireland’s Competent Authority team has 31 members, making it among the top three most resourced Competent Authority teams among the EU jurisdictions included in the report. The Irish Competent Authority team has grown substantially from a team of five in 2015. This growth shows the material investment made by Ireland over the last 10 years to resolve international tax disputes in an effective manner.
Takeaways
- In an effort to obtain certainty with respect to their transfer pricing arrangements, MNEs are increasingly seeking the certainty of an APA and this is a trend that we expect to continue. The 2024 APA statistics show that Ireland has made significant efforts to improve the timeframe to conclude cases. It is hoped that this timeframe to conclude cases will reduce in the coming years.
- The 2024 statistics also show that Ireland remains a highly effective MAP dispute resolution jurisdiction. Ireland’s results illustrate that even though taxpayer demand for MAP resolution is at an all-time high, the increase in Irish Competent Authority resources has grown in tandem with the demand and reflects the importance of effective dispute resolution to Ireland.
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. If you have any questions, please contact Mark O’Sullivan, Anna Crowley or your usual Matheson Tax contact.