OECD statistics clearly show that there are more cases of POPs. It can be inferred later that there are more audits and more adjustments. The result has been increased pressure on THE POPs themselves to improve the way it should work and to increase pressure on the competent authorities responsible for eliminating double taxation. According to statistics, 73% of map files closed in 2019 have successfully solved the controversial problem. Of which 73%: Although interesting and useful, the statistics provided do not necessarily show whether the map process works effectively in a given jurisdiction. For example, a small number of POPs cases may indicate that there are few controversies or may indeed be an indicator of tax management processes or dynamics that have led to cases not reaching POPs for one or more reasons. In particular, Article 19 of the compulsory arbitration procedure must be mandatory if the competent authorities are unable to reach an agreement on the settlement of a case within two years of their start. This is a significant restriction on POPs cases in the past, as the competent authorities were only required to try to resolve cases and disputes could be resolved indefinitely. Section 19 ensures that treaty disputes will be resolved within a specified time frame, making the MAP a more attractive option for taxpayers. In addition, sections 20 to 25 provide for the practical functioning of arbitration. In the past, it was often practical constraints or a lack of agreement on how to proceed that blocked the solution. The 2019 POPs statistics contain 21 other jurisdictions that have not been taken into account in 2018: Andorra, Angola, Aruba, Bahamas, Barbados, Belize, Bermuda, Bosnia and Herzegovina, British Virgin Islands, Cook Islands, Faroe Islands, Gibraltar, Greenland, Jordan, Liberia, Mongolia, Morocco, Nigeria, Ukraine, United Arab Emirates and Vietnam. In addition, pop 2019 statistics show members of the inclusive framework who have not yet submitted their map statistics for 2019.10 The OECD has also updated its interactive tool allowing users to compare the performance of countries surveyed in 2019 for each type of case (i.e.
transfer pricing or „other” cases). The comparison is based on seven key indicators: stock start, open files, closed business, end of inventory, time (in months), closing ratio11 and, for the first time, the proportion of files before 2016 (or pre-included) in the stock close. Users can customize their search by filtering them between indicators and selecting groups of legal systems. The statistics are only for KREMa and not for third countries. In the coming years, POP statistics will be collected as part of statistical data on disputes under the EU Directive EU 2017/1852 on tax dispute settlement mechanisms in the EU. Overall, it is clear that the MLI extends taxpayers` access to three years, both in terms of extending the period during which taxpayers must initiate a POB period, provides an effective two-year period for the relevant authorities to resolve a case (after that date, it may be subject to arbitration).