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APA report for 2024 shows consistent number of APAs executed in less time

28 March 2025

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Tax Alerts, Transfer Pricing, Transfer Pricing

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United States

The APMA Program issued its 26th report in Announcement 2025-13.The IRS received 169 APA requests in 2024, a slight increase from 167 in 2023, while 142 APAs were executed, down from 156 the previous year.The median time to complete a new bilateral APA decreased to 45.9 months, and the overall median time for all APAs dropped to 33.5 months.The APA Program remains a crucial tool for transfer pricing certainty, but potential staffing and budget cuts may impact the number of APAs executed in 2025. Executive summaryThe IRS Advance Pricing and Mutual Agreement (APMA) Program issued the 26th annual Advance Pricing Agreement...