Inside the 2025 IRS APMA Statistics

On 30 March 2026, the Internal Revenue Service (IRS) released Announcement 2026-8, the annual report on Advance Pricing Agreements (APAs) and the Advance Pricing and Mutual Agreement Program (APMA Program) for calendar year 2025. The report provides key statistical data and general descriptions of APA applications filed, executed, and pending, including the countries involved, types of transactions covered, transfer pricing methods used, and completion times.... By: DLA Piper