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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