The IRS today released Announcement 2025-13 providing the Advance Pricing and Mutual Agreement (APMA) program’s annual report on advance pricing agreements (APAs) for 2024.
This is the 26th report describing the experience, structure, and activities of the APMA program. The report does not provide guidance regarding the application of the arm’s length standard.
Announcement 2025-13 reports that:
- The number of executed APAs in 2024 was 142 (compared to 156 in 2023).
- In 2023, the percentage of APA renewals executed was 58% (compared to 47% in 2023).
- As in prior years, more than half of the APAs executed in 2024 involved transactions between non-U.S. parents and U.S. subsidiaries.
- Although most of the transactions covered in APAs executed in 2024 involved the sale of tangible goods or the provision of services, 22% involved the use of intangible property (noted by the IRS to be among the most challenging transactions in the APMA program’s inventory).
- The median time required to complete an APA continued to decrease in 2024 to 33.5 months (versus 42 months in 2023).