Sign up for tax alert emails    GTNU homepage    Tax newsroom    Email document    Print document    Download document

April 26, 2021

US IRS extends time for submitting APA and MAP requests with e-signatures

The United States (US) Internal Revenue Service (IRS) has extended the date by which advance pricing agreement (APA) and mutual agreement procedure (MAP) requests may be filed electronically with digital signatures until 31 December 2021.

On 15 April 2021, the IRS released an updated memo on e-signature requirements. The new memo is the same as an earlier memo issued 1 December 2020 (which had an expiration date of 30 June 2021) (See EY Global Tax Alert, US IRS announces modifications for filing APA and MAP requests, addresses questions on pending and executed APAs, dated 15 May 2020).

Filing modifications

These modifications affect the procedures for filing MAP request documents under Revenue Procedure 2015-40 and for filing APA requests and annual APA reports under Revenue Procedure 2015-41.

Under the modifications, documents requiring the taxpayer's signature under Revenue Procedure 2015-40 or Revenue Procedure 2015-41 may be submitted instead with either (1) a scanned or photographed image of the taxpayer's signature or (2) the taxpayer's digital signature created using encryption techniques.

In addition, taxpayers may electronically file submissions required under Revenue Procedure 2015-40 or Revenue Procedure 2015-41 rather than submitting paper copies.


The IRS's ability to adapt to the virtual environment by recognizing electronic signatures when submitting MAP or APA documentation demonstrates the flexibility afforded taxpayers during this time. Multinational taxpayers should examine their own books and records for opportunities to benefit from the certainty that these types of agreements can provide.


For additional information with respect to this Alert, please contact the following:

Ernst & Young LLP (United States), International Tax And Transaction Services – Transfer Pricing, Washington, DC


The information contained herein is general in nature and is not intended, and should not be construed, as legal, accounting or tax advice or opinion provided by Ernst & Young LLP to the reader. The reader also is cautioned that this material may not be applicable to, or suitable for, the reader's specific circumstances or needs, and may require consideration of non-tax and other tax factors if any action is to be contemplated. The reader should contact his or her Ernst & Young LLP or other tax professional prior to taking any action based upon this information. Ernst & Young LLP assumes no obligation to inform the reader of any changes in tax laws or other factors that could affect the information contained herein.


Copyright © 2024, Ernst & Young LLP.


All rights reserved. No part of this document may be reproduced, retransmitted or otherwise redistributed in any form or by any means, electronic or mechanical, including by photocopying, facsimile transmission, recording, rekeying, or using any information storage and retrieval system, without written permission from Ernst & Young LLP.


Any U.S. tax advice contained herein was not intended or written to be used, and cannot be used, by the recipient for the purpose of avoiding penalties that may be imposed under the Internal Revenue Code or applicable state or local tax law provisions.


"EY" refers to the global organisation, and may refer to one or more, of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients.


Privacy  |  Cookies  |  BCR  |  Legal  |  Global Code of Conduct Opt out of all email from EY Global Limited.


Cookie Settings

This site uses cookies to provide you with a personalized browsing experience and allows us to understand more about you. More information on the cookies we use can be found here. By clicking 'Yes, I accept' you agree and consent to our use of cookies. More information on what these cookies are and how we use them, including how you can manage them, is outlined in our Privacy Notice. Please note that your decision to decline the use of cookies is limited to this site only, and not in relation to other EY sites or Please refer to the privacy notice/policy on these sites for more information.

Yes, I accept         Find out more