What happened?
The IRS Advance Pricing and Mutual Agreement Program (APMA) on March 26 issued its 25th Annual Statutory Report Concerning Advance Pricing Agreements (APAs). The report shows there was a significant increase in the number of APAs executed in 2023, with the number more than doubling from 77 in 2022 to 156 in 2023, making 2023 a record year in the history of the APA program in terms of the number of executed APAs. For APAs completed in 2023, there was a slight improvement in the time to finalize APAs, decreasing slightly in 2023 to three and a half years, and down from the all-time recent high of approximately 43 months in 2022. The increase in executed APAs, coupled with the slight decrease in processing times, suggests continued improvement in the efficiency of the APA process four years after the COVID-19 pandemic.
External Link