Part II. APMA Program Statistical Data
Internal Revenue Bulletin 2017-15 · 2026-10-03 edition · updated 2026-10-04 · United States
[Pub. L. 106–170 § 521(b)(2)(C)(i–viii)]
Table 1: APA Applications Filed § 521(b)(2)(C)(i)
Unilateral Bilateral Multilateral Total Filed 1991–1999 4 401
Filed 2000–2015 542 1194 10 1746
Filed in 2016 14 84 0 98
Total Filed 1991–2016 2245
The table above illustrates the number of complete applications filed per year. As of December 31, 2016, APMA had also received 17 user fee filings that were not yet accompanied by substantially complete APA applications, in addition to the 98 complete APA applications.
4The first APA Statutory Report, which compiled APA data from 1991–1999, did not report the cumulative number of applications for those years by submission type, so the cumulative totals cannot be reported in that manner.
April 10, 2017 1078 Bulletin No. 2017–15
Table 2: Executed and Pending APAs § 521(b)(2)(C)(ii–vi)
Unilateral Bilateral Multilateral Total
Total Executed 1991–2015 539 958 14 1511
Total Executed in 2016 21 65 0 86
Total Executed 1991–2016 560 1023 14 1597
Total Pending 67 322 9 398
Renewals Executed in 2016 17 32 0 49
Renewals Pending 33 131 2 166
Of the 86 agreements executed in 2016, 41 percent were new APAs ( i.e., not a renewal of a prior APA). This was a slight increase from the 40 percent executed in 2015.
As the chart above illustrates, nearly three quarters of the total number of bilateral APAs executed in 2016 involved the United States entering into mutual agreements with either Japan or Canada.
Bulletin No. 2017–15 1079 April 10, 2017
The number of pending APAs dropped slightly from 2015 to 2016 with Japan and Canada continuing to account for almost half of all pending bilateral APAs.
April 10, 2017 1080 Bulletin No. 2017–15
Table 3: APAs Revoked or Cancelled and Applications Withdrawn
§ 521(b)(2)(C)(vii)
Unilateral Bilateral Multilateral Total
Revoked or Cancelled in 2016 0 0 0 0 Total Revoked or Cancelled 1991–2016 5 11
Applications Withdrawn in 2016 9 15 0 24 Total Applications Withdrawn 1991–2016 6 224
Table 4: APAs Finalized or Renewed 7 by Industry
§ 521(b)(2)(C)(viii)
Industry
Manufacturing 40
Wholesale/Retail Trade 33
Services 6
All Other Industries 7
Table 4a: Manufacturing APAs Finalized or Renewed 2016
Wholesale/Retail Trade
Computer and Electronic Products 7
Chemical 6
Transportation Equipment 6 Miscellaneous Manufacturing 8 9
All Other Types of Manufacturing 12
5The first APA Statutory Report, which compiled APA data from 1991–1999, did not report the cumulative number of applications for those years by submission type, so the cumulative totals cannot be reported in that manner.
6The first APA Statutory Report, which compiled APA data from 1991–1999, did not report the cumulative number of applications for those years by submission type, so the cumulative totals cannot be reported in that manner.
7APAs finalized or renewed are the same as APAs executed.
8Miscellaneous Manufacturing is NAICS code 339.
Bulletin No. 2017–15 1081 April 10, 2017
Table 4b: Wholesale/Retail Trade APAs Finalized or Renewed 2016
Wholesale/Retail Trade
Merchant Wholesalers, Durable Goods 21
Merchant Wholesalers, Nondurable Goods 9
All Other Types of Other Wholesale/Retail Trade 3
April 10, 2017 1082 Bulletin No. 2017–15
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