Rollback provisions under advance pricing agreements require modified returns, tax payment, and withdrawal of pending appeals. Rollback provisions under an Advance Pricing Agreement are implemented through filing of modified returns for the rollback years, along with proof of payment of any additional tax arising from the rollback computation. Pending appeals on the covered issue must be withdrawn by the applicant before filing the modified return, and appeals by the revenue authorities must be withdrawn within three months of the applicant's filing. The relevant appellate forum must also be informed of the agreement containing the rollback provision.