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Part II. APMA Program Statistical Data

Internal Revenue Bulletin 2021-15 · 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) 2

Unilateral Bilateral Multilateral Total
Filed 1991­19992 401
Filed 2000­2019 622 1,621 26 2,269
Filed in 2020 15 103 3 121
Total Filed 1991-2020 2,791

250

200

150

100

50

0

APA Applications Filed

2011-2020

2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

Bilateral APA Applications Filed

by Country

All Other Countries 18%

4%

Korea

4%

Japan

41%

Switzerland

5%

7%

India

Canada 11%

10%

The charts above illustrate the number of complete applications fi led per year and the bilateral requests received in 2020 by foreign country. As of December 31, 2020, APMA had also received 25 user fee fi lings that were not yet accompanied by substantially com­ plete APA applications, in addition to the 121 complete APA applications.

2 The fi rst APA Statutory Report, which compiled APA data from 1991­1999, did not report the cumulative number of applications for those years by submission type, so the cumulative totals cannot be reported in that manner.

Bulletin No. 2021–15 1013 April 12, 2021

Table 2: Executed 3 and Pending APAs § 521(b)(2)(C)(ii-vi) 45

150

100

50

0

Executed APAs

2011-2020

2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

Executed Bilateral APAs

by Country

All Other Countries

18%

Japan

52%

Denmark

4%

United Kingdom

7%

8%

India

11%

In 2020, the percentage of renewals executed remained fairly consistent (59 percent in 2020 versus 57 percent in 2019). The charts above illustrate the total number of APAs executed per year and the countries involved in the executed bilateral APAs.

3 Executed APAs refer to all APAs fi nalized or renewed.

4 The number of renewals executed is included in the total number of APAs executed during the year.

5 The number of renewals still pending as of year­end is also included in the total number of pending APAs.

April 12, 2021 1014 Bulletin No. 2021–15

500

400

300

200

100

0

Pending APAs

2011-2020

2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

Pending Bilateral APAs

by Country

All Other Countries Japan

Italy

4%

Mexico

10% 11%

As the top chart illustrates, the number of pending requests decreased slightly relative to December 31, 2019. As of December 31, 2020, over half of the pending bilateral APA requests involved either Japan, India, or Canada.

Table 3: APAs Revoked or Cancelled and Applications Withdrawn § 521(b)(2)(C)(vii) 67

Unilateral Bilateral Multilateral Total
Revoked or Cancelled in 2020 0 0 0 0
Total Revoked or Cancelled 1991-20206 11
Applications Withdrawn in 2020 2 5 0 7
Total Applications Withdrawn 1991-20207 272

6 The fi rst APA Statutory Report, which compiled APA data from 1991­1999, did not report the cumulative number of applications for those years by submission type, so the cumulative totals cannot be reported in that manner.

7 See supra note 6.

Bulletin No. 2021–15 1015 April 12, 2021

Table 4: APAs Executed in 2020 by Industry § 521(b)(2)(C)(viii)

APAs Executed in 2020 by Industry

Manufacturing

34%

Trade

31%

2%

Table 4a: Manufacturing APAs Executed in 2020

17%

Management

7% 9%

7%

and Real Estate

Manufacturing

Chemical Manufacturing 8
Transportation Equipment Manufacturing 8
Miscellaneous Manufacturing 7
Food Manufacturing 6
Computer and Electronic Product Manufacturing 5
Machinery Manufacturing 3
Plastics and Rubber Products Manufacturing 3
All Other Manufacturing 3

Manufacturing APAs

Executed in 2020

Transportation

Equipment

19% Miscellaneous Manufacturing

All Other Manufacturing

7%

Chemical

16% Food Manufacturing

Products

7%

Machinery Manufacturing

7%

14% Computer and

11%

Manufacturing

April 12, 2021 1016 Bulletin No. 2021–15

Table 4b: Wholesale/Retail Trade APAs Executed in 2020

Wholesale/Retail Trade

Merchant Wholesalers, Durable Goods 24
Merchant Wholesalers, Nondurable Goods 8
Electronics and Appliance Stores 5
All Other Wholesalers 3

All Other

8%

Wholesale/Retail Trade APAs

Executed in 2020

Electronics and Appliance Stores

12%

Merchant Wholesalers, Durable

Goods

Wholesalers, Nondurable Goods

20%

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