CRA notes that around half of its recent MAP cases resulted in full relief

CRA provided the following statistics on MAPs for the 2020 calendar year:

• … The average time to complete a negotiable MAP case was 17.83 months;
• Of the 74 MAP cases closed in 2020, 36 cases (i.e., 48.6%) resulted in full relief from double taxation upon negotiation, 9 cases (i.e., 12.2%) had objections not justified, and 8 cases (i.e., 10.8%) were resolved through unilateral relief. The remaining 21 cases (i.e., 28.4%) were either withdrawn by the taxpayers, resolved via domestic remedy, resulted in no agreement or were denied MAP access;
• Of the 74 MAP cases closed in 2020, 60 (i.e., 81%) were initiated by Canada and 14 (i.e., 19%) were initiated by countries other than Canada;

Neal Armstrong. Summary of 17 May 2022 IFA Roundtable, Q.13 under Treaties – Income Tax Conventions – Art. 26.