Part II. APMA Program Statistical Data
Internal Revenue Bulletin 2022-15 · 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) 3
| Unilateral | Bilateral | Multilateral | Total | |
|---|---|---|---|---|
| Filed 1991-19993 | 401 | |||
| Filed 2000-2020 | 637 | 1,724 | 29 | 2,390 |
| Filed in 2021 | 16 | 121 | 8 | 145 |
| Total Filed 1991-2021 | 2,936 |
250
200
150
100
50
0
Applications Filed
2012-2021
2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
Bilateral APAs Filed per Country 2021
China
3%
China All Other Countries
3%
Korea
4%
5%
7%
Canada 16%
10%
The charts above illustrate the number of complete applications fi led per year and the bilateral requests received in 2021 per foreign country. As of December 31, 2021, APMA had also received 29 user fee fi lings that were not yet accompanied by substantially complete APA applications, in addition to the 145 complete APA applications.
3 The fi rst 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 11, 2022 948 Bulletin No. 2022–15
Table 2: Executed 4 and Pending APAs § 521(b)(2)(C)(ii-vi) 56
| Unilateral | Bilateral | Multilateral | Total | |
|---|---|---|---|---|
| Total Executed 1991-2020 | 662 | 1,385 | 20 | 2,067 |
| Total Executed in 2021 | 25 | 98 | 1 | 124 |
| Total Executed 1991-2021 | 687 | 1,483 | 21 | 2,191 |
| Total Pending as of 12/31/2021 | 39 | 395 | 27 | 461 |
| Renewals Executed in 20215 | 19 | 59 | 0 | 78 |
| Renewals Pending6 as of 12/31/2021 | 26 | 147 | 12 | 185 |
150
100
50
0
APAs Executed
2012-2021
2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
Bilateral APAs
Japan
3%
China
3%
5%
20%
6%
7%
In 2021, the percentage of renewals executed increased (63 percent of all APAs executed in 2021 versus 59 percent in 2020). The charts above illustrate trends in the number of APAs executed per year and the countries involved in the bilateral APAs that were executed in 2021.
4 Executed APAs refers to all APAs fi nalized or renewed.
5 The number of renewals executed is included in the total number of APAs executed during the year.
6 The number of renewals still pending as of year-end is also included in the total number of pending APAs.
Bulletin No. 2022–15 949 April 11, 2022
500
400
300
200
100
0
Pending APAs
2012-2021
2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
Pending Bilateral APAs
by Country 2021
All Other Countries
Japan
Mexico
5%
4%
Korea
5%
5%
11%
5%
As the top chart illustrates, the number of pending requests increased slightly relative to December 31, 2020. As of December 31, 2021, almost 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) 78
| Unilateral | Bilateral | Multilateral | Total | |
|---|---|---|---|---|
| Revoked or Cancelled in 2021 | 0 | 0 | 0 | 0 |
| Total Revoked or Cancelled 1991-20217 | 11 | |||
| Applications Withdrawn in 2021 | 1 | 4 | 1 | 6 |
| Total Applications Withdrawn 1991-20218 | 279 |
7 The fi rst 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.
8 See supra note 7.
April 11, 2022 950 Bulletin No. 2022–15
Table 4: APAs Executed in 2021 by Industry § 521(b)(2)(C)(viii)
Industry
| Manufacturing | 46 |
|---|---|
| Wholesale/ |
47 |
| Services | 17 |
| Management | 8 |
| Finance, Insurance, and Real Estate | 4 |
| All Other Industries | 2 |
APAs Executed in 2021 by Industry
Manufacturing
37%
2%
Wholesale/Retail
Trade
38%
Management 14%
and Real Estate
6%
3%
Table 4a: Manufacturing APAs Executed in 2021 9
Type of Manufacturing
| Transportation Equipment | 17 |
|---|---|
| Chemical | 10 |
| Computer and Electronic Products | 5 |
| Miscellaneous9 | 4 |
| Machinery | 3 |
| All Other Manufacturing | 7 |
9 Industries in the Miscellaneous Manufacturing subsector (NAICS Code 339) make a wide range of products that cannot readily be classifi ed in specifi c NAICS manufacturing subsectors.
Bulletin No. 2022–15 951 April 11, 2022
Type of Manufacturing APAs
Executed in 2021
Chemical
Transportation
Computer and Electronic Products
Equipment
37%
11%
All Other Manufacturing
15%
6%
Miscellaneous
9%
Table 4b: Wholesale/Retail Trade APAs Executed in 2021
Type of Wholesale/Retail Trade
| Merchant Wholesalers, Durable Goods | 29 |
|---|---|
| Merchant Wholesalers, Nondurable Goods | 9 |
| Motor Vehicle and Parts Dealers | 4 |
| All Other Wholesalers | 5 |
All Other
11%
Type of Wholesale/Retail Trade APAs
Executed in 2021
Motor Vehicle and
Parts Dealers
Merchant Wholesalers, Durable
8%
Goods
Wholesalers, Nondurable Goods
19%
April 11, 2022 952 Bulletin No. 2022–15
Nature of the Relationships § 521(b)(2)(D)(i)
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