US signs fewer APAs in 2014

The US IRS signed significantly fewer advance pricing agreements (APAs) in 2014 as compared to the two previous years, according to statistics released by the goverment on March 30.

The total of 101 APAs were signed in 2014, as compared to 145 in 2013 and 140 in 2012.

Of APAs signed in 2014, 81 were bilateral, zero were multilateral, and 20 were unilateral. In contrast, in 2013, bilateral APAs signed totaled 105, one multilateral APA was signed, and 39 unilateral APAs were signed.

The percentage of new APAs signed, as opposed to renewals, increased over the previous year, the goverment noted. In 2014, 52 APAs were new and 48 were renewals.

The median time required to complete bilateral APAs executed in 2014 showed a small decrease whereas unilateral APAs executed in 2014 experienced a small increase in the median time to complete as compared with 2013.

The median time to complete both types of APA in 2014 was 35.3 months.

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