US eases APA, MAP filing requirements

On May 11, 2020, the US Internal Revenue Service (IRS) announced certain modifications to procedures for filing of documents when making mutual agreement procedure (MAP) and advance pricing agreement (APA) requests. 

Any documents requiring the taxpayer's signature may be submitted with either an image of the taxpayer's signature (scanned or photographed) or the taxpayer's digital signature created using encryption techniques to provide proof of original and unmodified documentation. Either form of signature is acceptable.

All submissions may be filed electronically; paper copies are not required.

With regard to questions about pending and executed APAs, the tax authority is actively discussing various substantive and procedural issues with treaty partners, including such technical issues as the application of transfer pricing methods in periods of economic distress and the impacts of current economic conditions on specific industries, types of taxpayer, regions, etc.

See Announcement