Part II. APMA Program Statistical Data

[Pub. L. 106-170 § 521(b)(2)(C)(i-viii)]

Table 1: APA Applications Filed § 521(b)(2)(C)(i)

250

200

150

100

50

0

Applications Filed

2014-2023

2014 2015 2016 2017 2018 2019 2020 2021 2022 2023

All Other Countries

16%

Bilateral APAs Filed by Country 2023

Japan

Australia

3%

Mexico

3%

United Kingdom

5%

Italy

8%

Canada

14%

The charts above illustrate the number of complete applications fi led per year and the percentage of bilateral requests received in 2023 per foreign country. As of December 31, 2023, APMA had also received 22 user fee fi lings that were not yet accompanied by a substantially complete APA application, in addition to the 167 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.

Bulletin No. 2024–16 911 April 15, 2024

Table 2: Executed ⁴ and Pending APAs § 521(b)(2)(C)(ii-vi)

200

150

100

50

0

APAs Executed

2014-2023

2014 2015 2016 2017 2018 2019 2020 2021 2022 2023

Bilateral APAs Executed by Country 2023

Japan

32%

3%

United Kingdom

6%

6%

8% 11%

India

17%

In 2023, the percentage of renewals executed decreased (47 percent of all APAs executed in 2023 versus 55 percent of all APAs executed in 2022). 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 2023.

4 “Executed APAs” refers to APAs that were fi nalized and includes both initial and renewal APAs.

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.

April 15, 2024 912 Bulletin No. 2024–16

600

500

400

300

200

100

0

Pending APAs

2014-2023

2014 2015 2016 2017 2018 2019 2020 2021 2022 2023

Pending Bilateral APAs

by Country

Japan

4%

Italy

5%

Canada

India

23%

5%

13%

6%

As the top chart illustrates, the number of pending requests decreased slightly relative to December 31, 2022. As of December 31, 2023, 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Table 3: APAs Revoked or Cancelled and Applications Withdrawn § 521(b)(2)(C)(vii)

7 The fi rst APA Statutory Report, which compiled APA data from 1991-1999, and the second APA Statutory Report, which compiled APA data for 2000, 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.

Bulletin No. 2024–16 913 April 15, 2024

Table 4: APAs Executed in 2023 by Industry § 521(b)(2)(C)(viii)

APAs Executed in 2023 by Industry

Manufacturing

31%

4%

Wholesale/Retail

Trade

30%

Services

17%

Management

6% 12%

6%

and Real Estate

Table 4a: Manufacturing APAs Executed in 2023

Type of Manufacturing

Type of Manufacturing APAs

Chemical

Transportation

Executed in 2023

Equipment

Computer and Electronic Product

31%

17%

All Other Manufacturing

17%

6%

10%

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.

April 15, 2024 914 Bulletin No. 2024–16

Table 4b: Wholesale/Retail Trade APAs Executed in 2023

Type of Wholesale/Retail Trade

Type of Wholesale/Retail Trade APAs

Executed in 2023

All Other Wholesalers

15%

Merchant Wholesalers, Durable

Clothing and Clothing Accessories

53%

Goods

Stores

11%

Merchant

Nondurable Goods

21%

Bulletin No. 2024–16 915 April 15, 2024

Nature of the Relationships § 521(b)(2)(D)(i)