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29 January 2024

User fee for advance pricing agreements increases effective February 2, 2024

The IRS has increased the user fee to apply for an advance pricing agreement (APA) beginning on February 2, 2024.

In Revenue Procedure 2024-1, which is the annual update for procedures for filing letter rulings, determination letters and information letters, the IRS increased the user fees for APAs as follows:

  • Original APA: $121,600 (from $113,500)
  • Renewal APA: $65,900 (from $62,000)
  • Small Case APA: $57,500 (from $54,000)
  • APA Amendment: $24,600 (from $23,000)

Under the dollar-file-request option in Revenue Procedure 2015-41, APA requests are considered filed by a particular date if (1) the correct user fee is paid by the applicable date, and (2) a complete APA request is filed within 120 days of that date (with a 30-day extension for good cause and the request is made within the 120-day period).

Implications

Taxpayers that were planning to file an APA request soon may pay the current user fee by paying before February 2, 2024, and following the dollar-file-request procedure.

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Contact Information

For additional information concerning this Alert, please contact:

National Tax Department, International Tax and Transactions Services, Transfer Pricing

Published by NTD’s Tax Technical Knowledge Services group; Andrea Ben-Yosef, legal editor

Document ID: 2024-0289

 

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