Executive answer
The OECD’s 2024 MAP statistics provide a common view of inventories, cases started, cases closed, outcomes and timing. In the published global aggregate, transfer pricing cases show an average of 30.89 months. That figure signals that MAP can be a multiyear process; it does not predict how long Mexico or a particular file will take.
A CFO should combine global data, Mexico’s jurisdictional information, the MAP profile, treaty, facts, deadline, double taxation, case-file quality, domestic remedies and implementation capacity. A statistic is a scenario and resourcing reference, not legal analysis or a promise of relief.
Verification cutoff: August 2, 2026. The data concern 2024 and were published by the OECD in 2025. Check revisions and later statistics before presenting figures to the board.
What the dataset measures
The framework reports opening and closing inventory, starts, closures, outcomes and time. It distinguishes transfer pricing from other cases and separates old and new populations under agreed reporting methods.
Read definitions before comparing. Similar labels can conceal different bases.
The 30.89-month average
This is the global average completion time for transfer pricing cases in the 2024 data. It is not a median, statutory deadline or automatic Mexican estimate.
A distribution can include very short and very long cases. Do not build a budget on one number.
Global and Mexican data
Aggregates provide system context; Mexico’s entry shows its reported inventory and activity. Compare years and categories carefully.
Do not divide inventory by closures and call it a probability. They are flows, not identical cohorts.
Opening inventory
It represents open cases at the start under report definitions. A high inventory can reflect demand, complexity, old cases or limited capacity.
It is not automatically poor performance.
Cases started
New entries during the year may vary because of audits, treaties, the economy or administrative changes.
They do not imply final acceptance of every request or a favorable result.
Cases closed
Closure includes different forms of completion. Analyze outcome categories rather than treating every closure as full elimination of double tax.
A case may close by agreement, unilateral relief, withdrawal, denial or another reported reason.
Request an assessment that turns statistics into timing, cost, cash flow, relief and governance scenarios without confusing averages with commitments.
Closing inventory
It reflects starts, closures and adjustments. Compare series, not two isolated numbers, and read methodological notes.
Growth can warrant more conservative resourcing but does not forecast one file.
Outcomes
Classify full or partial elimination, unilateral relief, no agreement, withdrawal and other official outcomes. Decide which categories relate to the exposure.
Do not combine incompatible categories to create a promotional “success rate.”
Average time
The average helps plan reserves and teams. Build short, base and long scenarios and replace assumptions with actual milestones.
Avoid “MAP takes 31 months.” State that the reported global category average was 30.89 months.
Mexico in context
Compare Mexican activity with the counterparty jurisdiction because both authorities affect the case. The MAP profile provides contacts and guidance; the treaty establishes access and framework.
A counterparty with substantial inventory may also influence the process.
Applicable treaty
Statistics do not confirm access. Read the MAP article, deadline, taxes, residence and measures.
Preserve the first-notification date. A favorable average cannot rescue a late request.
Case complexity
Years, transactions, countries, methods, languages, data and remedies matter. One loan is not comparable with a multilateral restructuring.
Assign a complexity rating and explain timing scenarios.
File quality
A reconciled file can reduce taxpayer-controlled delays, although it cannot guarantee speed. Track missing documents, versions, translations and reproducibility.
Statistics do not cure internal contradictions.
Resources
Budget personnel, advisers, translation, valuation, travel, guarantees and compliance over several years. Appoint backups.
Sunk cost should not force continuation if possible relief changes.
Cash flow
Model tax paid, secured, interest, refund and timing. Use several horizons rather than the average alone.
Treasury and accounting approve assumptions.
Reserves
Statistics can inform scenarios but do not determine accounting recognition. Document facts and applicable policy.
Update after an act, agreement, payment or probability change.
Interaction with litigation
MAP and domestic remedies may coexist under conditions. The duration of one does not determine the other. Coordinate timelines.
Do not abandon a defense because of aggregated data.
Partial relief
Model 25%, 50%, 75% and 100%, plus denial or withdrawal. Include additions and indirect effects.
The statistical category may not capture the full economic impact.
Executive dashboard
Fields include double tax, treaty, deadline, inventory, timing scenario, cost, reserve, payment, milestones, documents, potential outcome, residual exposure and decision.
Update quarterly or when events occur.
Time comparison
Compare 2024 with prior years only where definitions align. Explain methodological and population changes.
Do not infer causation without evidence.
Pre- and post-2016 cases
The OECD separates populations under the reporting framework. Do not blend old and new inventory without notes.
Reconciliation aims to reduce double counting in the newer population.
Internal metrics
Track days from request, company response time, questions, reconciliations, cost and exposure. Compare against the plan rather than ranking countries.
Controllable metrics improve governance.
Decision thresholds
Define when to escalate, accept partial resolution, seek information, revise a reserve or exit a route under applicable procedures. Base thresholds on amount and facts.
Do not turn the average into an artificial deadline.
Board communication
Present ranges, assumptions and sources. Separate the global average, Mexico data and the team’s inference. Explain what the company controls.
Avoid charts without a denominator or date.
Warning signs
Warnings include using an average as a guarantee, mixing transfer pricing and other cases, inventing a success rate, ignoring methodology, comparing incompatible years, omitting treaty analysis or citing data without cutoff.
Correct before publication.
Reading checklist
Confirm year, publication, category, unit, population, definition, jurisdiction, counterparty, outcome, average, notes, revision and source.
Separate the reported figure, internal calculation and inference.
Illustrative example
A foreign adjustment creates material double tax. The CFO sees the global 30.89 months but does not adopt it as the closing date. The team creates 18-, 31- and 48-month scenarios, validates the treaty, preserves a remedy and funds the case file.
Every quarter it replaces assumptions with actual milestones.
MAP Feasibility Memo product
The deliverable covers access, deadline, double tax, file, statistical context, scenarios, cost, cash flow, remedies, governance and recommendation. Every statistic carries a source and limitation.
It does not promise duration or success.
2025 update
When 2025 data appear, retain the 2024 version and log changes. Do not overwrite history.
Check methodology before recalculating trends.
Scenario approval gate
Management signs the source date, selected range, financial assumptions and events that trigger revision. The case lead reports actual progress against the range without labeling a variance as authority failure.
This keeps the statistics in their proper role: planning under uncertainty, not prediction.
Building quantitative scenarios
Begin with double taxation by year and currency. Add principal tax, interest, penalties, adviser fees, guarantee cost, internal effort and time value. Assign short, base and long horizons. The global average can inform the base case but should not be the sole rationale.
For each horizon model zero, partial and full relief. Separate the agreement date from the refund or effective implementation date. A technical resolution may take additional domestic steps before cash is recovered.
Document assumptions and sensitivities. If exposure changes with exchange rates, interest or tax losses, show the range. The board then sees economic uncertainty rather than false precision.
Reading outcome categories
Use the official table and preserve original labels. Create an internal dictionary for fully eliminating agreement, partial agreement, unilateral relief, withdrawal, denial and other categories. Translation should retain meaning.
Do not classify every agreement as success. Compare relief with the claim, cost and residual exposure. Partial closure can be rational; quick closure without relief should not artificially improve a metric.
Counterparty comparison
A Mexico-country B case depends on two inventories, profiles, teams and treaties. Prepare a card for each jurisdiction covering contacts, guidance, statistics, language, domestic remedies and relevant experience. Identify classification and calendar differences.
Do not average both countries’ times into a forecast. Use the information to detect constraints and plan coordination. If the counterparty does not publish comparable data, state the limitation.
Internal cohorts
Where the group has several MAP cases, create cohorts by start year, transaction, countries, amount and status. Measure taxpayer-controlled and authority time only where records permit. Do not compare a closed case with an early-stage file as if they were equivalent.
Internal cohorts support budgeting and knowledge retention. They should not be published as representative statistics for Mexico without a sufficient base.
Statistical data governance
Assign an owner to download, archive and verify each edition. Preserve the source sheet, date, filters and calculations. A second reviewer reproduces every percentage shown to the board. Label OECD data, company calculations and team inferences separately.
If the OECD revises a figure, issue a visible correction and update affected scenarios. Do not silently alter history.
Adversarial dashboard review
Before presentation, ask a reviewer to find missing denominators, misleading scales, averages without dispersion, incorrectly combined categories and mixed dates. The chart should disclose source and cutoff without oral explanation.
Include a panel titled “what these data do not say”: case admission, individual duration, outcome, cost, cash date and litigation effect. The limitation belongs on the dashboard rather than in fine print.
Quarterly update gate
Every quarter, replace assumptions with real milestones: request filed, acceptance, information delivered, authority interaction, proposal or implementation. If nothing changed, retain the range and explain why.
A timing variance triggers review of resources and reserves, not an automatic conclusion about probability. Distinguish taxpayer-controlled delay from institutional waiting.
Scenario support file
Retain the official download, source table, formulas, currency conversion, assumptions and approval. Link every dashboard figure to the source file. A second reviewer reproduces results before the meeting.
When the range changes, record the event supporting it. Planning remains auditable rather than appearing to be a prediction revised to confirm expectations.
Archive the approved version for later comparison and learning.
Conclusion
The 2024 MAP statistics add discipline to planning by showing scale, flow and system timing. Their usefulness ends where individual prediction begins.
For Mexico, combine them with the treaty, profile, counterparty and file. The data then inform a decision without becoming a promise.
Request a MAP Feasibility Memo to translate access, double tax, statistics, scenarios, resources and remedies into an executive route.
Verified official sources
- OECD, 2024 mutual agreement procedure statistics.
- OECD, MAP profiles, including Mexico.
- OECD, Manual on Effective Mutual Agreement Procedures 2026.
- SAT, tax treaties and related matters.
Verification closed on August 2, 2026. Aggregated data do not forecast an individual file.