IRS Advance Pricing Agreement Backlog Grew After Departures (1)

The IRS completed fewer advance pricing agreements last year after departures from the agency’s Advance Pricing and Mutual Agreement Program, worsening a growing backlog of pending agreements amid increased demand from taxpayers.

APMA executed 110 advance pricing agreements in 2025, according to the office’s annual report released Monday, down from 142 the year before and 156 in 2023. APAs apply to transfer pricing arrangements—valuing transactions between related companies for taxation purposes.

The decline came as staffing levels at the office fell to 108, from 126 in 2024, after last year’s widespread cuts and departures at the agency.

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