Part II. APMA Program Statistical Data
Internal Revenue Bulletin 2019-15 · 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 2 401
Filed 2000–2017 570 1,364 11 1,945
Filed in 2018 35 161 7 203
Total Filed 1991–2018 2,549
The charts above illustrate the number of complete applications filed per year and the bilateral requests received in 2018 by foreign country. As of December 31, 2018, APMA had also received 71 user fee filings that were not yet accompanied by substantially complete APA applications, in addition to the 203 complete APA applications.
2The 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.
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Table 2: Executed and Pending APAs § 521(b)(2)(C)(ii-vi)
Unilateral Bilateral Multilateral Total
Total Executed 1991–2017 590 1,108 15 1,713
Total Executed in 2018 24 81 2 107
Total Executed 1991–2018 614 1,189 17 1,820
Total Pending as of 12/31/2018 58 387 13 458 Renewals Executed in 2018 3 15 45 2 62 Renewals Pending 4 36 158 1 195
Consistent with prior years, roughly 40 percent of the APAs executed in 2018 were new APAs ( i.e., not a renewal of a prior APA). The charts above illustrate the total number of APAs executed per year and the countries involved in the executed bilateral APAs. Over half of the bilateral APAs executed in 2018 involved mutual agreements with either Japan or Canada.
3The number of renewals executed is included in the total number of APAs executed during the year.
4The number of renewals still pending as of year-end is also included in the total number of pending APAs.
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As the top chart illustrates, the number of pending requests continues to rise due largely to the increase in number of requests filed. As of December 31, 2018, over half of the pending bilateral APA requests involved either Japan or India.
Table 3: APAs Revoked or Cancelled and Applications Withdrawn § 521(b)(2)(C)(vii)
Unilateral Bilateral Multilateral Total
Revoked or Cancelled in 2018 0 0 0 0 Total Revoked or Cancelled 1991–2018 5 11
Applications Withdrawn in 2018 7 14 0 21 Total Applications Withdrawn 1991–2018 6 253
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.
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Table 4: APAs Executed 7 by Industry § 521(b)(2)(C)(viii)
Industry
Manufacturing 48
Wholesale/Retail Trade 35
Management 8
Services 7
Finance, Insurance, and Real Estate 4
All Other Industries 5
7APAs executed include APAs that were renewed.
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Table 4a: Manufacturing APAs Executed in 2018
Manufacturing Miscellaneous Manufacturing 8 10
Transportation Equipment 9
Computer and Electronic Products 6
Machinery 6
Chemical 5
All Other Types of Manufacturing 12
Table 4b: Wholesale/Retail Trade APAs Executed in 2018
Wholesale/Retail Trade
Merchant Wholesalers, Durable Goods 24
All Other Types of Other Wholesale/Retail Trade 11
8Miscellaneous Manufacturing is NAICS code 339.
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