Inside the 2025 IRS APMA Statistics

On 30 March 2026, the Internal Revenue Service (IRS) released Announcement 2026-8, the annual report on Advance Pricing Agreements (APAs) and the Advance Pricing and Mutual Agreement Program (APMA Program) for calendar year 2025. The report provides key statistical data and general descriptions of APA applications filed, executed, and pending, including the countries involved, types of transactions covered, transfer pricing methods used, and completion times.

While the total number of executed APAs declined compared to the previous year, the data suggests that demand for transfer pricing certainty continues to increase year-on-year, with bilateral APAs dominating the program. At the same time, the report points to increasing pressure on capacity, particularly in light of reduced staffing levels within the APMA Program. Against this backdrop, taxpayers considering the APA route will need to adopt a more strategic approach to managing scope, timing, and outcomes.

 

Key statistics at a glance

 

APMA staffing and structure

As of 31 December 2025, the APMA Program’s APA caseload was managed by 108 staff members: 63 team leaders, 30 economists, 12 managers, and 3 assistant directors. This represents a decrease of 18 from the 126 staff reported at the end of 2024. Each assistant director oversees four managers who lead teams of team leaders and economists.

The reduction in headcount may partly explain the decrease in executed APAs during 2025. Notwithstanding this, the program’s geographic footprint and organizational structure remain robust, and the IRS has shown a willingness in recent years to invest in the program’s capacity.

 

Applications filed and pending

APMA received 178 complete APA applications in 2025 (23 unilateral, 153 bilateral, and 2 multilateral), up from 169 in 2024. An additional 31 user fee filings were received that were not yet accompanied by a substantially complete application. The continued high volume of filings reflects sustained demand from multinational enterprises for advance certainty on transfer pricing.

The pending APA inventory grew to 622 (61 unilateral, 543 bilateral, and 18 multilateral) as of 31 December 2025, compared to 560 at the end of 2024. Slightly less than half of the pending bilateral cases involved Japan or India.

The top countries for bilateral APA filings in 2025 were India (26%), Japan (24%), Italy (8%), Canada (7%), Korea (7%), Germany (5%), Mexico (4%), the United Kingdom (4%), Switzerland (3%), and Denmark (2%).

 

Executed APAs

A total of 110 APAs were executed in 2025 (14 unilateral, 90 bilateral, and 6 multilateral), compared to 142 in 2024 and the record 156 in 2023. While this represents a decline, it remains well above historical averages prior to the program’s recent expansion. Of the 110 executed APAs, 55 (50%) were renewals, down from 58% in 2024.

The top countries involved in bilateral APAs executed in 2025 were India (35%), Japan (25%), Canada (11%), Germany (5%), Korea (5%), Ireland (3%), Switzerland (3%), and the United Kingdom (3%).

 

Notable shifts in 2025

• Balanced relationship types. In a notable change, 2025 saw an equal split between APAs involving transactions between US parents and non-US subsidiaries (45%) and those between non-US parents and US subsidiaries (45%), with sister companies accounting for the remaining 10%. In prior years, transactions involving non-US parents and US subsidiaries consistently represented more than half of executed APAs (e.g. 56% in 2024).

• Services transactions dominate. The majority of covered transactions in 2025 involved the provision of services (53% combined: 30% by non-US entities and 23% by US entities). The sale of tangible property into the US accounted for 20%, with the use of intangible property comprising 17% combined.
• Non-US service providers as tested parties. Non-US service providers comprised 41% of tested parties in 2025, up significantly from 31% in 2024. US distributors, manufacturers, and service providers combined fell to 48% from 59% in 2024.

 

Industry breakdown

Wholesale and retail trade led the industry breakdown at 29%, followed by services (25%), manufacturing (20%), management (15%), and finance, insurance and real estate (7%). Within wholesale/retail trade, merchant wholesalers of durable goods were the largest subcategory (44%).

 

Transfer pricing methods

The comparable profits method / transactional net margin method (CPM/TNMM) continued to be the most widely applied method for transactions involving the sale of tangible property and the use of intangible property, used in 86% of such cases. The operating margin remained the most common profit level indicator at 57%, with the Berry Ratio and return on sales making up a further 20%. For services transactions, the CPM/TNMM was applied 83% of the time with operating margin and operating profit-to-operating expense ratio being the most common profit level indicators.

 

Completion times

Average completion time increased to 44.1 months in 2025, up from 39.1 months in 2024. The median also rose to 41.6 months from 33.5 months in the prior year.

New bilateral APAs took an average of 50.0 months (median 46.4), while renewals averaged 37.5 months (median 39.8).

In our view, the longer completion times likely reflect a combination of factors, including the resolution of more complex cases during the year, delays in assessing and negotiating the impact of tariffs (particularly important given that transactions involving tangible goods comprise a significant number of cases), and the impact of reduced staffing levels within the APMA Program.

 

APA term lengths

The average APA term in 2025 was six years. Five-year terms remained the most common (41 of 110 APAs), consistent with the guidance in Rev. Proc. 2015-41 recommending at least five prospective years. Of the APAs executed in 2025, 23% included rollback years, down from 28% in 2024.

 

Implications for multinational enterprises

The statistics confirm that the APA program remains a valuable tool for multinational enterprises seeking certainty in their transfer pricing. Key takeaways include:

• Sustained demand: The increase in applications filed (178 in 2025 vs 169 in 2024) indicates continued confidence in the program as a dispute prevention mechanism.
• Growing backlog: The rising inventory of pending APAs (622 vs 560) suggests that the program’s throughput has not kept pace with demand, underscoring the importance of strategic engagement with APMA to move cases forward efficiently.
• India and Japan remain dominant: These two countries continue to represent the largest share of bilateral APA activity, both in filings and executed agreements.
• Services transactions in focus: The shift toward services as the primary covered transaction type reflects broader trends in the global economy and increased tax authority scrutiny of intercompany service arrangements.
• Proactive engagement is critical: While reported average completion times may seem long, our experience confirms that a strategic, proactive approach, including early engagement with APMA and the relevant foreign competent authority, can significantly reduce timelines.

At DLA Piper, we continue to see the APA program as an important tool for multinational groups seeking prospective transfer pricing certainty and dispute prevention, particularly where bilateral relief can materially reduce double tax risk. The 2025 statistics reinforce that APAs remain highly relevant, but they also underline the importance of choosing the right cases, building the factual record early, and engaging with APMA with a clear strategy on timing and treaty-partner dynamics.

Please contact us if you would like to learn more, and for more information on APAs and MAPs processes and acceptance criteria by jurisdiction please visit our APA & MAP Country Guide.