OECD/G20税基侵蚀与利润转移项目 提高争议解决机制有效性——相互协商程序综合信息2025

Making Dispute ResolutionMechanisms More Effective–Consolidated Information onMutual Agreement Procedures 2025 Preliminary version OECD/G20 Base Erosion and Profit Shifting Project Making Dispute Resolution MechanismsMore Effective – Consolidated Informationon Mutual Agreement Procedures (CIM) 2025 This document is a preliminary version ofMaking Dispute Resolution More Effective – Consolidated Information onMutual Agreement Procedures 2025. The final version will include an overview of the jurisdiction’s MAP statistics for2024, as well as APA statistics where relevant, and will be made available on the same link by 17 November 2025. This document, as well as any data and map included herein, are without prejudice to the status of or sovereignty overany territory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area. The statistical data for Israel are supplied by and under the responsibility of the relevant Israeli authorities. The use ofsuch data by the OECD is without prejudice to the status of the Golan Heights, East Jerusalem and Israeli settlementsin the West Bank under the terms of international law. Note by the Republic of Türkiye The information in this document with reference to “Cyprus” relates to the southern part of the Island. There is nosingle authority representing both Turkish and Greek Cypriot people on the Island. Türkiye recognises the TurkishRepublic of Northern Cyprus (TRNC). Until a lasting and equitable solution is found within the context of the UnitedNations, Türkiye shall preserve its position concerning the “Cyprus issue”. Note by all the European Union Member States of the OECD and the European Union The Republic of Cyprus is recognised by all members of the United Nations with the exception of Türkiye. Theinformation in this document relates to the area under the effective control of the Government of the Republic ofCyprus. Please cite this document as: OECD (2025),Making Dispute Resolution More Effective - Consolidated Information on Mutual Agreement Procedures 2025,OECD/G20 Base Erosion and Profit Shifting Project, https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/dispute-resolution/consolidated-information-on-mutual-agreement-procedures-2025.pdf. Photo credits: Cover ©giggsy25/Shutterstock.com Corrigenda to OECD publications may be found online at: www.oecd.org/about/publishing/corrigenda.htm.© OECD 2025 Foreword Digitalisation and globalisation have had a profound impact on economies and the lives of people aroundthe world, and this impact has only accelerated in the 21st century. These changes have brought with themchallenges to the rules for taxing international business income, which have prevailed for more than ahundred years and created opportunities for base erosion and profit shifting (BEPS), requiring bold movesby policy makers to restore confidence in the system and ensure that profits are taxed where economicactivities take place and value is created. In 2013, the OECD ramped up efforts to address these challenges in response to growing public andpolitical concerns about tax avoidance by large multinationals. The OECD and G20 countries joined forcesand developed an Action Plan to address BEPS in September 2013. The Action Plan identified 15 actionsaimed at introducing coherence in the domestic rules that affect cross-border activities, reinforcingsubstance requirements in the existing international standards, and improving transparency as well ascertainty. After two years of work, measures in response to the 15 actions, including those published in an interimform in 2014, were consolidated into a comprehensive package and delivered to G20 Leaders in November2015. The BEPS package represents the first substantial renovation of the international tax rules in almosta century. The implementation of BEPS measures strengthens the international tax system by ensuringthat BEPS planning strategies identified that relied on outdated rules or on poorly co-ordinated domesticmeasures have been rendered ineffective. OECD and G20 countries also agreed to continue to work together to ensure a consistent and co-ordinatedimplementation of the BEPS recommendations and to make the project more inclusive. As a result, theycreated the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework), bringing all interested andcommitted countries and jurisdictions on an equal footing in the OECD Committee on Fiscal Affairs and itssubsidiary bodies. With over 145 members, the Inclusive Framework monitors and peer reviews theimplementation of the minimum standards and is advancing the work on standard setting to address furtherBEPS issues. In addition to its members, other international organisations and regional tax bodies areinvolved in the work of the Inclusive Framework, which also consults business and the civil society on itsdifferent work streams. The work to address BEPS has also led to further c