Treasurer Stacy Garrity Announces Improvements to Pennsylvania Tax Appeal Process

Extended time to appeal and new mediated settlement process available for certain state tax appeals.

Pennsylvania Treasurer Stacy Garrity today announced numerous improvements to Pennsylvania’s tax appeals process which will benefit Pennsylvania taxpayers. The changes apply to tax appeals filed on or after January 27, 2025, when Act 123 of 2024, which amended the Tax Reform Code of 1971, took effect.

“These are significant improvements which make the tax appeal process more fair for hardworking Pennsylvanians and businesses,” Treasurer Garrity said. “The new law removes unnecessary bureaucratic obstacles – and it will save both the state and its taxpayers time and money. I want to thank Sen. Scott Hutchinson, Rep. Tim Briggs, and every member of the General Assembly who supported these important changes with tremendous bipartisanship.”

Pennsylvanians seeking to resolve tax disputes with the Department or Revenue (DOR) for personal income taxes, fiduciary income taxes, employer withholding taxes and pass-through assessments will now have 90 days (previously 60) to file their appeals with the Board of Finance & Revenue (BF&R). BF&R can also grant a 30-day extension for late-filed applications for these types of tax appeals if good cause is shown.

In addition, taxpayers filing certain appeals will be able to request a mediated settlement conference at no cost to them. Those requesting a mediated settlement conference have 30 calendar days to do so following the filing of their tax appeal. BF&R also has the discretion to refer an appeal to a mediated settlement conference.

This new mediated settlement process will reduce litigation costs for taxpayers and serve as an alternative to formal, lengthy and costly court appeals. Treasury estimates that up to 500 cases annually could be eligible for this new process.

Act 123 of 2024 was supported by numerous organizations, including the Pennsylvania Institute of Certified Public Accountants, the Pennsylvania Chamber of Business and Industry, the NFIB, and the Pennsylvania Society of Enrolled Agents. The new law was sponsored by Sen. Hutchinson (R-21) and earned great bipartisan support in the General Assembly. A companion bill was introduced in the House by Rep. Briggs (D-149).

BF&R is an independent administrative tax tribunal, administered by the State Treasurer, responsible for the second and final level of administrative appeal (with minor exceptions) before appealing to court. Its Board consists of three members – two are appointed by the Governor and confirmed by the Pennsylvania Senate; the third is the State Treasurer or her designee and serves as Chair.

For further guidance on procedures to request a mediated settlement conference, visit patreasury.gov/bfr.