Despite adding personnel and making a concerted effort to speed up the advance pricing agreement process, the Advance Pricing and Mutual Agreement Program (APMA) faces challenges with the mounting demand. Our International Tax Group breaks down the hurdles for APMA and identifies important trends companies negotiating APAs should keep in mind.
- APMA staff increased 21% last year, but median completion time for an APA increased to 35 months (up from 33 months in 2020)
- APMA would need more than three years to work through its existing inventory of bilateral APAs at its current processing rate
- The mountain of work keeps growing: more APA applications, but fewer APAs executed
Read the full advisory here.