The IRS has improved its Pre-Filing Agreement programme to offer large businesses and international taxpayers greater tax certainty, emphasising cooperative strategies to prevent disputes early.
The US Internal Revenue Service (IRS) issued IR-2025-69 on 17 June 2025, announcing improvements to its Pre-Filing Agreement (PFA) programme to provide greater tax certainty for large businesses and international taxpayers.
These improvements mark a renewed commitment by the IRS to expand access to cooperative tax compliance strategies that prevent disputes before they arise.
The IRS Pre-Filing Agreement Program (PFA) is a proactive tool available to taxpayers within the jurisdiction of the IRS’s Large Business and International division (LB&I). The programme allows LB&I taxpayers to resolve potential tax issues before filing their return. This agreement offers tax certainty, reduces audit risks, and encourages voluntary compliance.
The PFA programme allows taxpayers under the Large Business and International Division jurisdiction to resolve potential tax issues before filing their return, offering certainty, reducing audit risk, and encouraging voluntary compliance. If accepted into the program, there is a user fee of USD 181,500.
Key enhancements to the Pre-Filing Agreement programme include:
- A redesigned PFA landing page with programme statistics, a streamlined process overview and direct navigation to dispute prevention resources.
- New step-by-step instructions to submit a PFA request, including response time expectations and post-submission next steps.
- A dedicated Pre-Filing Agreement (PFA) likely suitable issues and documentation page will help taxpayers identify if a PFA request is appropriate for their situation.
- Updated programme guidelines to help businesses strategically align their PFA submissions with tax filing deadlines.
