US: APMA program statistics for 2014

US: APMA program statistics for 2014

The IRS today released an advance version of Announcement 2015-11 providing the annual report on the advance pricing and mutual agreement (APMA) program for 2014 and containing advance pricing agreement (APA) statistics for 2014.

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Announcement 2015-11 [PDF 884 KB] reports that:

  • The number of executed APAs in 2014 was 101—compared to 140 in 2012 and 145 in 2013.
  • The median completion time for unilateral and bilateral APAs was 35.3 months for new APAs and renewed APAs combined.
  • The number of executed APAs (101) did not surpassed the number of applications filed (108) during 2014.

APA statistics for 2014

 

unilateral

 

bilateral

multilateral



total





Applications filed



31 74 3 108




APAs executed



20 81 0 101




APAs pending



62 268 6 336




Renewals executed in 2014



9 39 0 48




Renewals pending



28 119 2 149




Revoked or cancelled



0 0 0 0




Applications withdrawn



0 1 0 1

The total of 108 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 2014, the IRS reports that the APMA program had received 33 user fee filings in addition to the 108 complete APA applications. 

 

For more information, contact a professional with KPMG’s Global Transfer Pricing Services Group:

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

Clark Chandler | +1 (202) 533-3186 | cchandler@kpmg.com

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