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

2016-2025

2016 2017 2018 2019 2020 2021 2022 2023 2024 2025

Bilateral APAs

India

26%

Switzerland

3%

4%

Mexico

4%

Germany

5%

7% 7%

7%

7% 8%

Italy

The charts above illustrate the number of complete applications fi led per year and the percentage of bilateral requests received in 2025 per foreign country. As of December 31, 2025, APMA had also received 31 user fee fi lings that were not yet accompanied by a substantially complete APA application, in addition to the 178 complete APA applications.

2 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. 2026–16 815 April 13, 2026

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

200

150

100

50

0

APAs Executed

2016-2025

2016 2017 2018 2019 2020 2021 2022 2023 2024 2025

Bilateral APAs Executed by Country 2025

India

35%

United Kingdom

3%

Ireland

3%

3%

Korea

5%

5%

11%

Canada 25%

In 2025, the percentage of APA renewals executed decreased (50 percent of all APAs executed in 2025 versus 58 percent of all APAs executed in 2024). 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 2025.

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

4 The number of renewals still pending as of year-end is also included in the total number of pending APAs.

April 13, 2026 816 Bulletin No. 2026–16

800

600

400

200

0

Pending APAs

2016-2025

2016 2017 2018 2019 2020 2021 2022 2023 2024 2025

Pending Bilateral APAs

by Country

Japan

United Kingdom

4%

Germany

Italy

5%

4%

Korea

6%

6% 11%

6%

India

21%

As the top chart illustrates, the number of pending requests increased compared to December 31, 2024. As of December 31, 2025, slightly less than 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Table 3: APAs Revoked or Cancelled and Applications Withdrawn § 521(b)(2)(C)(vii)

5 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.

6 See supra note 5.

Bulletin No. 2026–16 817 April 13, 2026

Table 4: APAs Executed in 2025 by Industry § 521(b)(2)(C)(viii)

Industry

APAs Executed in 2025 by Industry

Manufacturing

20%

Wholesale/Retail

Trade

29%

Services

25%

4%

Management

15%

and Real Estate

7%

Table 4a: Wholesale/Retail Trade APAs Executed in 2025

Type of Wholesale/Retail Trade

Type of Wholesale/Retail Trade APAs

Executed in 2025

44%

Merchant General Merchandise Wholesalers, Stores Nondurable Goods 15% 19%

April 13, 2026 818 Bulletin No. 2026–16