Skip to content

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/Retail Trade 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)

Get a plain-English answer with a citation back to this text.

Ask AI about this code
▸Contents — Internal Revenue Bulletin 2022-15

GoCodebook provides public access, search, citation, multilingual explanation, and practical interpretation of legally adopted building regulations. It is not a substitute for the official ICC or California code publications.