Pop 2019 statistics include the number of POPs cases each jurisdiction has with each of its contractual partners, and the performance of the jurisdiction empowered to report on key indicators for each type of case can be compared by an interactive tool. Pop statistics 2017 are now available for 85 countries and almost all map cases worldwide. They contain detailed information on the different jurisdictions and aggregated global information. Among the highlights, the MLI was adopted on November 24, 2016. There are already 100 signatories and parties to the MLI, which came into force on July 1, 2018. In order to promote the widest possible acceptance, the MLI has flexible functions that must enable countries to adapt their adoption to their situation and take into account the unique aspects of their contractual network. In order for the MLI to amend a bilateral tax treaty, both parties (i) must have signed and ratified the IML and (ii) have established the contracts that must be covered by the LML. While some of the MLI items are mandatory, most are optional. Legal systems, for example, can only adopt minimum standards or adopt some or all of the optional articles. According to the RFB manual, express acceptance and proof of resignation must be made within 30 days of notification of the MAP result. Failure to comply with the legal provisions terminates the procedure by withdrawing the applicant and prevents the admission of a new POP application for the same purpose. The process of mutual unification (POP) remains the most widely used way and the best way to eliminate double taxation. The effective use of PPIs by different instruments has been of interest to the OECD and the EU for more than 20 years.
According to bePS, the number of double taxes is increasing and the number of POPs continues to increase. There is a growing emphasis on ensuring better dispute resolution techniques to more effectively eliminate double taxation. This article describes some of the features of the instruments currently available. OECD publishes procedural statistics for the 2016 Mutual Consent Procedure The BePS 14 (Making Dispute Resolution Mechanisms More Effective) report provides for the requirement for legal systems to set a minimum standard to ensure that they resolve treaty disputes in a timely, effective and effective manner. All members of the Integrated Framework for BEPS (IF) are committed to implementing the minimum standards of Action 14, which include a rapid and comprehensive report on the statistics of the Mutual Agreement Procedure (MAP), in accordance with an agreed report framework. Pop 2019 statistics will be published as part of this new framework. They cover all members who joined the IF before 2020. The appendix to this warning contains summary tables that provide an overview of POP statistics for 2016, 2017 and 2018. In September 2019, the OECD published POP statistics for 2018. It should be noted that OECD statistics on POPs show that more taxpayers are using the map procedure in the face of increased bilateral tax controls and disputes.
The MLI has helped to improve the efficiency and effectiveness of the map process, in line with the intentions expressed in the final report of 5 years ago. If we consider only cases before 1 January of the year of membership of the inclusive framework (or the period prior to 1 January of the year of membership to the inclusive framework), the exit inventory and closed cases have been reduced: if we look at the statistics for all POPs cases (transfer pricing and “other” cases, as well as the two cases received before January 1, 2016 or January 1 of the membership year included , as well as cases that were received on or after the date). , there have been increases in the initial inventory, the closing of inventory and closed cases: some may argue that the existence of arbitration is that the existence of this mechanism encourages Member States to settle disputes before the expiry of the two-year period, which would be a success rather than a failure of the convention.