Are the Top Five Economies on Top of Advance Pricing Agreements? A Statistical Analysis

This article statistically analyses whether prominent objectives of the advance pricing agreement (APA) programme are being met in the top five economies of the world and rates the scale of satisfaction with grades of high, medium or low. The analysis highlights the high pendency of APAs wherein the average rate of disposal is inordinately long, even in renewal cases, thereby causing stagnation in the APA programme itself. Even though renewal of APAs conveys the confidence of taxpayers in the APA regimes, which is most heartening, at this pace, renewal cases will outnumber new APA filings going forward and may discourage fresh filings since tax administrations shall largely remain occupied with processing renewal cases only. In order to reinvigorate the APA regime, the article recommends, with reasons, that tax administrations may consider amending the rules and increasing the number of covered years to up to ten years in cases pertaining to renewal of APAs.

Authors

Publication Details

Journal
International Transfer Pricing Journal
Published
2026-05-08
DOI
https://doi.org/10.59403/3chfcfr
Primary Topic
Corporate Taxation and Avoidance
Type
article
Field-Weighted Citation Impact
0.00
Controls
|||
ALL TIME
JAN
FEB
MAR
APR
MAY
JUN
JUL
AUG
SEP
OCT
article

Are the Top Five Economies on Top of Advance Pricing Agreements? A Statistical Analysis

Kuldeep Sharma
International Transfer Pricing Journal
Corporate Taxation and Avoidance
article

Are the Top Five Economies on Top of Advance Pricing Agreements? A Statistical Analysis

Kuldeep Sharma
article en

Abstract

This article statistically analyses whether prominent objectives of the advance pricing agreement (APA) programme are being met in the top five economies of the world and rates the scale of satisfaction with grades of high, medium or low. The analysis highlights the high pendency of APAs wherein the average rate of disposal is inordinately long, even in renewal cases, thereby causing stagnation in the APA programme itself. Even though renewal of APAs conveys the confidence of taxpayers in the APA regimes, which is most heartening, at this pace, renewal cases will outnumber new APA filings going forward and may discourage fresh filings since tax administrations shall largely remain occupied with processing renewal cases only. In order to reinvigorate the APA regime, the article recommends, with reasons, that tax administrations may consider amending the rules and increasing the number of covered years to up to ten years in cases pertaining to renewal of APAs.

International Transfer Pricing JournalVol. 33(3)
Partnerships for the goals
Openalex Percentile: Top 4%
Corporate Taxation and Avoidance
AI Navigator

Ask Laika to Summarize, Analyze, and Connect papers live on the map.

Summarize Papers & Methodologies

Extract key findings, datasets, and comparative methods across publications.

Benchmark Rankings & Visual Analytics

Rank top research institutions, authors, funders, topics, and journals by Field-Weighted Citation Impact (FWCI) and paper volume with instant charts.

Connect Distant Disciplines

Bridge topological clusters on the map to find hidden collaborative intersections.