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Announcement 2019-03: APMA program, APA statistics for 2018

Announcement 2019-03: APMA program, APA statistics

The IRS today released an advance version of Announcement 2019-03 providing the annual report on the advance pricing and mutual agreement (APMA) program for 2018 that contains advance pricing agreement (APA) statistics for 2018.

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Announcement 2019-03 [PDF 1.6 MB] reports that:

  • The number of executed APAs in 2018 was 107—compared to 116 in 2017. Of the 107 APAs executed in 2018, approximately 40% were new APAs (and not renewals of a prior APA).
  • The number of executed APAs (107) fell behind the number of applications filed (203) during 2018, adding to APMA’s backlog of pending APA requests.
  • The median completion time for new APAs and renewed APAs combined was 40.2 months (unilateral and bilateral APAs).  
  • The number of pending requests continues to rise due largely to the increase in number of requests filed. As of December 31, 2018, over half of the pending bilateral APA requests involved either Japan or India. 

APA statistics for 2018

 

 

Unilateral

Bilateral

Multilateral

Total

Applications filed

35

161

7

203*

APAs executed

24

81

2

107

APAs pending

58

387

13

458

Renewals executed in 2018

15

45

2

62

Renewals pending

36

158

1

195

Revoked or cancelled

0

0

0

0

Applications withdrawn

7

14

0

21


*The total of 203 include the number of complete applications filed per year and the bilateral requests received in 2018 by foreign country. As of December 31, 2018, APMA had also received 71 user fee filings that were not yet accompanied by substantially complete APA applications, in addition to the 203 complete APA applications.

 

For more information, contact a tax professional with KPMG’s Global Transfer Pricing Services group in the United States:

Sean Foley | +1 (202) 533-5588 | sffoley@kpmg.com

Mark Martin | +1 (713) 319-3976 | mrmartin@kpmg.com 

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