From the inception of the APA program in 1991 until December 31, 2019, the IRS received a total of 2,670 APP applications and executed 1,940 APAs. In the table below, you will find summary statistics on APP applications for 2019, exported APAs and pending AAPs. Data are reported separately for unilateral and bilateral APAs and completion times for 2019, 2018 and 2017 are compared. The following data show that the average completion time for new bilateral APAs has decreased slightly, from 47.8 months in 2018 to 47.2 months in 2019. The average time to complete the new unilateral APA has increased from 35.4 months in 2018 to 33.8 months in 2019. Time to close the APP: In general, The Chinese tax authorities try to conclude unilateral and bilateral APAs within 12 and 24 months of formal applications. The most unilateral APAs (89%) and bilateral APAs (62%) The Commission concluded agreements between 2005 and 2019, within two years of the date of formal application. In 2019, most of the new APA agreements were concluded within two years of the formal application date. It should be noted that five of the nine new bilateral APAs were finalized in 2019 within just one year of its formal application. This is reflected in the STA`s commitment to ensuring effective negotiation and conclusion of the APA by providing sufficient resources to manage the APA`s affairs. The number of APA applications has decreased, with taxpayers submitting 121 APA applications in 2019, compared to 203 in 2018.
This decline is not surprising, as APMA has significantly increased user fees for companies applying for a PAA from 2018. The total number of completed APAs increased from 107 to 120 and the median completion period decreased slightly from 40.2 months to 38.8 months. A very important aspect of an APA program is the time that has been spent processing an application and reaching an agreement. We calculated this by taking into account the time between the date the application was filed and the date the agreement was signed. Different countries have been able to reach different deadlines for concluding APAs. For example, the United States has an average schedule of 35.4 months for unilateral APAs and 47.8 months for bilateral APAs in 2018.