International Tax

What fees are involved in obtaining an APA?

The user fee for original requests for an APA for taxpayers with a gross income of US$1 billion or more is $25,000, and $6,500 for each additional multilateral request.  Renewals require a $7,500 user fee.  Designated small transactions require a $7,500 fee.  Taxpayers with gross income less then $1 billion and greater than or equal to $100 million are required to submit $15,000 for an original request, $7,500 for each additional multilateral request, $7,500 for each routine renewal, and $7,500 for small transaction APAs.  Taxpayers with a gross income of less then $100 million are required to submit $5,000 for an original request.

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