TP Ticker – August 2019

Statistics on APAs and MAPs in the EU

In July 2019, the EU Joint Transfer Pricing Forum (“EUJTPF”) published statistics for Advance Pricing Agreements (“APAs”) in the EU at the end of 2018.  These statistics detail for 28 member states and the EU in total items such as the number of APAs in force, granted over the year, rejected applications and withdrawals, and the average time to negotiate an APA.  This cover unilateral- as well as multilateral APAs and provide for each state a breakdown according to APAs with EU-member states and non-EU states.  For example, the country with the most APAs in force at the end of 2018, was Belgium with a sum of 507.  However, the vast majority of these were unilateral APAs of which 306 related to transactions with EU member states and 181 with non-EU states.  The Belgian tax administration received over the year 424 APA requests and granted 378.  Only one APA request was rejected in 2018 and 8 withdrawn by the taxpayer.  Belgian APAs required on average 15 month of negotiation time, where EU states were involved and 27 months, where the transaction with the Belgian taxpayer was with a non-EU jurisdiction.

The EUJTPFs statistics on APAs can be found on the website of the European Union here: https://ec.europa.eu/taxation_customs/system/files/2019-07/apa-and-map-2019-3.pdf