Are the Top Five Economies on Top of Advance Pricing Agreements? A Statistical Analysis
- Kuldeep Sharma
- May 31
- 1 min read
I am privileged to inform that the IBFD has published my article titled “Are the Top Five Economies on Top of Advance Pricing Agreements? A Statistical Analysis” in its International Transfer Pricing Journal 2026 (Volume 33), No. 3.
The article statistically analyses whether the prominent objectives of introducing the APA programme are being met in the top five economies of the world, namely, the United States, China, Germany, Japan and India respectively. An in-depth exploration over several years has been made comprising the number of APA applications filed, cases disposed (including renewal cases), the average time period of disposal, overall pendency of APAs, and other pertinent data available in the public domain. As a result, satisfaction of prominent objectives of introducing the APA programme in the top five economies has been rated with grades of high, medium or low.
The APA programme has matured in all the countries analysed. However, it is observed that despite headline numbers of APA disposals looking fantastic, the programme, with the exception of Japan, is stagnating. This inference is duly supported by cogent insights. In order to reinvigorate the APA regime, the article makes a well-reasoned recommendation which all stakeholders may consider for adoption.
The article may be accessed at the following link:
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