Bloomberg Tax
May 11, 2020, 10:25 PM

IRS OKs Electronic Filing of Intercompany Pricing Documents

Rossella Brevetti
Rossella Brevetti

Companies can digitally sign and submit electronic copies of documents relating to their intercompany pricing arrangements during the coronavirus pandemic, the IRS said.

Paper requests won’t be required for advance pricing agreements, the contracts companies sign with the government to approve their transfer pricing, and mutual agreement procedures, the negotiations governments undertake to avoid a company being taxed twice on the same income, the Monday announcement said.

  • The IRS Advance Pricing and Mutual Assistance program, which handles APAs and MAPs, also is speaking with treaty partner countries about substantive and procedural issues relating to APAs. Such technical issues include “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.,” the announcement said.
  • Questions on executed APAs covering 2020 should be directed to the appropriate APMA assistant director, while questions on pending APAs should be directed to the assigned APMA team leader, the agency said.
  • The announcement comes after the IRS said it was allowing taxpayers to submit electronic requests for private letter rulings and other legal advice.

—With assistance from Isabel Gottlieb.

To contact the reporter on this story: Rossella Brevetti in Washington at

To contact the editors responsible for this story: Meg Shreve at; Sony Kassam at