Completed Advance Pricing Agreements at IRS Dipped Last Year

The IRS completed fewer advance pricing agreements last year, the chief of the office that handles them said Wednesday in a preview of the group’s annual report.

John Wall, director of the agency’s Advance Pricing and Mutual Agreement Program, declined to give numbers, as the report is still being finalized, but said the number of APAs completed in 2025 lagged the previous two years. He spoke after a panel at an Eversheds Sutherland event.

Companies request APAs to get their transfer pricing and tax positions effectively pre-blessed by tax authorities and avoid tax disputes. The agreements can be unilateral — ...