US Tax Authority Increases APA User Fees

The US Internal Revenue Service (IRS) has increased user fees for advance pricing agreement (APA) requests filed from July 1, 2018, with a further increase from January 1, 2019.

By Alex Cooper

The US Internal Revenue Service (IRS) has increased user fees for advance pricing agreement (APA) requests filed from July 1, 2018, with a further increase from January 1, 2019.

APAs filed after June 30, 2018

According to a revised schedule released by the IRS on February 6, 2018, the user fees for new APA requests filed from July 1, 2018, will be increased to USD86,750. Currently, as per Rev. Proc. 2015-41, this amount is USD60,000.

The current fee of USD35,000 for each request to renew an APA has also been increased to USD48,500. Additionally, the fees for small case APA requests and amendments to current APAs has been increased from USD30,000 and USD12,500 to USD42,500 and USD17,750, respectively.

APAs filed after December 31, 2018

Next, the user fees will be further increased from January 1, 2019. As per the updated fee schedule, fees for new APA requests filed from January 1, 2019, will be USD113,500.

The fee for each request to renew an APA will be increased to USD62,000, and fees for small case APA requests and amendments to current APAs will be increased to USD54,000 and USD23,000, respectively.

The IRS said: “By law, federal agencies are required to charge a user fee to recover the cost of providing certain services to the public that confer a special benefit to a recipient.”

The author is editorial assistant, TP News