U.S. IRS Releases APA Report Showing Increase in APA Applications and Drop in APA Executions

The U.S. IRS has issued Announcement 2026-08, the Announcement and Report Concerning Advance Pricing Agreements. The report describes the experience, structure, and activities of the Advance Pricing and Mutual Agreement Program during the calendar year 2025. As compared to 2024, 2025 saw an increase in APA applications filed from 169 to 178, along with a decrease in APAs executed from 142 to 110. 2025 also saw an increase in the median completion time for new and renewal APAs from 33.5 month…