The US Internal Revenue Service (IRS) released Announcement 2025-13 – Announcement and Report Concerning Advance Pricing Agreements on 27 March 2025.

The report outlines the experience, structure, and activities of the Advance Pricing and Mutual Agreement Program in 2024.

This Announcement is issued under the Ticket to Work and Work Incentives Improvement Act of 1999, which requires the Secretary of the Treasury to report annually to the public concerning advance pricing agreements (APAs) and the Advance Pricing and Mutual Agreement Program (APMA Program), formerly known as the Advance Pricing Agreement Program (APA Program).

The first report covered calendar years 1991 through 1999. Subsequent reports covered each calendar year from 2000 through 2023 separately. This twenty-sixth report describes the experience, structure, and activities of the APMA Program during calendar year 2024. It does not provide guidance regarding the application of the arm’s length standard.

Part I of this report includes information on the structure, composition, and operation of the APMA Program; Part II presents statistical data; and Part III includes general descriptions of various elements of the APAs executed in 2024, including types of transactions covered, transfer pricing methods used, and completion time.

In 2024, APA applications increased slightly from 167 to 169, while executed APAs fell from 156 to 142. The completion times improved significantly, decreasing from 42 months in 2023 to 33.5 months in 2024.

In 2024, the most common countries in bilateral APA applications were India (26%) and Japan (32%). They also accounted for the highest percentage of executed APAs (India 29%, Japan 23%) and pending APAs (India 22%, Japan 28%). Additionally, the report features the model APA, which remains unchanged from last year’s edition.