Overview
The annual Announcement and Report Concerning APAs for 2025 is the 27th report of its kind issued by APMA. Each annual report provides statistical data and general descriptions with respect to APA applications filed and executed during the previous calendar year, as well as the structure, composition and operation of the APMA Program.
As multinational corporations seek to gain certainty with respect to their worldwide transfer pricing policies, the demand for APAs reached a record high. APAs are agreements that allow taxpayers to preemptively agree with one or more tax authorities on arm’s-length prices for related-party transactions. An executed APA determines the best transfer pricing methodology and establishes results that satisfy the arm’s-length standard. Generally, an APA covers a five-year prospective term; however, some APAs with rollback terms can reach up to 15-year terms.
APA applications reach record high
During 2025, APMA received a record 178[1] APA applications, marking a steady increase from the 169 filings in 2024 and 167 filings in 2023. This growth reflects a sustained appetite for tax certainty in an increasingly complex economic landscape. Consistent with historical trends, most of these filings—approximately 86%—were bilateral in nature, demonstrating a clear preference for gaining clarity in multiple treaty jurisdictions. The primary jurisdictions for bilateral APA applications during 2025 included India (26%), Japan (24%), Italy (8%), Canada (7%) and Korea (7%).
APA execution in 2025
As of Dec. 31, 2025, the APMA Program’s professional staff consisted of 108 individuals, including three assistant directors, 12 managers, 30 economists and 63 team leaders, which represents a slight reduction from the 126 professionals reported in 2024. During 2025, a total of 110 APAs were executed, which was a decline from the high number of executed APAs in 2024 and 2023. Consequently, the pending inventory rose to 622 active cases by year-end, of which 310 were renewals. Reflecting government shutdowns and staffing shifts, the median time frame to execute an APA rose to 41.6 months in 2025, compared with 33.5 months in 2024. However, the 2025 timeline was consistent with the 2023 median time frame of 42.0 months.
From an industry perspective, the wholesale and retail trade and service sectors were the most common, accounting for 54% of all executed agreements. The composition of covered transactions saw a shift in 2025, with the provision of services now representing the majority at 53%, followed by the sale of tangible goods at 28%. Transactions involving intangible property accounted for approximately 17% of executed APAs; however, APMA continues to note that these cases remain among the most complex and resource-intensive in its inventory, often requiring significant technical analysis.
Conclusion
As evidenced by the record number of APA applications filed in 2025, the APA process remains a vital and proactive strategy for taxpayers seeking to gain greater certainty and mitigate tax exposure and the costs associated with protracted audit defense. While the latest statistics show an increase in execution timelines, the record-high number of APA applications underscores their value as a premier mechanism for resolving cross-border disputes. In an environment of heightened global enforcement, APAs provide a structured, nonadversarial alternative that can help multinational enterprises to achieve long-term fiscal stability and operational certainty.
