US: APMA program, APA statistics for 2015

US: APMA program, APA statistics for 2015

The IRS today released an advance version of Announcement 2016-12 providing the annual report on the advance pricing and mutual agreement (APMA) program for 2015 that contains advance pricing agreement (APA) statistics for 2015.

Related content

Announcement 2016-12 [PDF 906 KB] reports that:

  • The number of executed APAs in 2015 was 110—compared to 101 in 2014, 145 in 2013, and 140 in 2012.
  • The median completion time for unilateral and bilateral APAs was 31.9 months for new APAs and renewed APAs combined.
  • The number of executed APAs (110) did not surpassed the number of applications filed (183) during 2015.

APA statistics for 2015

  unilateral bilateral Multilateral total
Applications filed
52 127 4 183*
APAs executed 30 80 0 110
APAs pending 85 316 9 410
Renewals executed in 2015 18 48 0 66
Renewals pending 40 146 2 188
Revoked or cancelled 0 0 0 0
Applications withdrawn 4 6 0 10

*The total of 183 does not include situations when the taxpayer had paid a user fee but has not yet submitted a substantially complete APA request. As of 31 December 2015, the IRS reports that the APMA program had received 14 user fee filings in addition to the 183 complete APA applications.

KPMG observation

Initial impressions of today’s release of the APMA and APA statistics include: (1) that the APMA is resolving more APAs, in particular given an improved negotiating relationship between the United States and Japan; (2) that the increased number of APA filings may be due to the focus on base erosion and profit shifting (BEPS) actions and IRS guidance issued in August 2015 as Rev. Proc. 2015-40 and Rev. Proc. 2015-41; and (3) that the increasing inventory of pending APAs may be an area of some concern.

 

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

Steven Wrappe | +1 (408) 367-4185 | swrappe@kpmg.com

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