KPMG article: APAs in 2025

In a certain sense, 2025 was an annus horribilis for the IRS’s advance pricing agreement (APA) program. Cutbacks in IRS resources directly affected the advance pricing and mutual agreement (APMA) organization, albeit to a lesser extent than many of the agency’s other groups. Over the course of the year, the APMA program lost 14% of its workforce. Employees’ ability to travel for critical meetings was often difficult and uncertain. Tariffs complicated, and in some cases prevented the resolution of APAs in the docket. And to top it all off, the government went through a record-setting 43-day shutdown, during which most of all APMA personnel were furloughed, except for a skeleton crew.

It is encouraging, then, to see that the statistics in APMA’s recent report on the APA program for 2025 show resilience rather than collapse. While the statistics unsurprisingly fall short of some of the high points from 2024, a longer-term view shows that, relative to historical levels, APMA still employs a sizeable workforce and made significant progress in resolving APAs during 2025. Indeed, when one takes into account the significant headwinds that buffeted APMA in 2025, the statistics appear extremely impressive. One key challenge for the future will be effectively managing the growing inventory of pending cases, as taxpayer interest in the program remains strong.

Read an April 2026 article* that examines the IRS’s 2025 annual report on APAs and analyzes how, despite operational constraints from the government shutdown and the effects of tariffs, APAs remain a critical tool for managing transfer pricing uncertainty.

*This article appears in Tax Notes Federal (April 27, 2026) and is provided with permission.