US: APMA program, APA statistics for 2016 | KPMG | BE

US: APMA program, APA statistics for 2016

US: APMA program, APA statistics for 2016

The IRS today released an advance version of Announcement 2017-03 providing the annual report on the advance pricing and mutual agreement (APMA) program for 2016 that contains advance pricing agreement (APA) statistics for 2016.

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Announcement 2017-03 [PDF 564 KB] reports that:

  • The number of executed APAs in 2016 was 86—compared to 110 in 2015.
  • The median completion time for unilateral and bilateral APAs was 32.8 months for new APAs and renewed APAs combined.
  • The number of executed APAs (86) did not surpassed the number of applications filed (98) during 2016.

APA statistics for 2016

  Unilateral Bilateral Multilateral Total
Applications filed 14 84 0 98*
APAs executed 21 65 0 86
APAs pending 67 322 9 398
Renewals executed in 2016 17 32 0 49
Renewals pending 33 131 2 166
Revoked or cancelled 0 0 0 0
Applications withdrawn 9 15 0 24

*The total of 98 include the number of complete applications filed per year. As of December 31, 2016, the IRS reports that the APMA program had also received 17 user fee filings that were not yet accompanied by substantially complete APA applications, in addition to the 98 complete APA applications.

KPMG observation

Initial impressions of APMA and APA statistics include: (1) APA resolutions are down somewhat while APMA focuses on the APA process, (2) APA filings have returned to historic levels after last year’s exceptionally high filings fueled by a new APA Revenue Procedure and based erosion and profit shifting (BEPS) concerns, (3) an unexplained increase in APAs withdrawn, and (4) Japan continues to dominate bilateral APAs executed, filed and inventory, with India filings slightly exceeding Japan filings for the first time.

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