TREE NEWS reports: OECD data show negotiators resolved a record number of cross-border tax disputes through the mutual agreement procedure (MAP) in 2025, with nearly two-thirds of cases closed last year eliminating double taxation entirely. The figures also show an increase in advance pricing arrangements (APAs), through which taxpayers obtain pre-approval of their transfer pricing arrangements for a set period to gain certainty.
OECD: Record Number of Cross-Border Tax Disputes Resolved in 2025
AI take
The record MAP closures matter less as a dispute-resolution statistic than as a signal on transfer pricing risk, which sits at the center of how crypto and digital-asset groups structure cross-border operations. The rise in APAs points to taxpayers buying certainty in advance rather than litigating after the fact — a shift worth tracking as digital-asset firms scale into multiple jurisdictions. Whether the APA momentum holds as those business models mature is the open question.
Generated by AI for reference only.
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