
The IRS today released an advance version of Announcement 2018-08 providing the annual report on the advance pricing and mutual agreement (APMA) program for 2017 that contains advance pricing agreement (APA) statistics for 2017.
Announcement 2018-08 [PDF 1.43 MB] reports that:
Unilateral | Bilateral | Multilateral |
Total |
|
Applications filed |
14 | 86 | 1 | 101* |
APAs executed |
30 | 85 | 1 | 116 |
APAs pending |
57 | 321 | 8 | 386 |
Renewals executed in 2017 |
22 | 48 | 0 | 70 |
Renewals pending |
29 | 133 | 2 | 164 |
Revoked or cancelled |
0 | 0 | 0 | 0 |
Applications withdrawn |
1 | 6 | 1 | 8 |
*The total of 101 include the number of complete applications filed per year. As of December 31, 2017, the IRS reports that the APMA program had also received 37 user fee filings that were not yet accompanied by substantially complete APA applications, in addition to the 101 complete APA applications.
Some initial impressions of these APA statistics are:
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 (202) 533-3077 | swrappe@kpmg.com
Mark Martin | +1 (703) 319-3976 | mrmartin@kpmg.com
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