BILATERAL APAS

The Central Board of Direct Taxes (CBDT) has entered into a record 125 Advance Pricing Agreements (APAs) with Indian taxpayers in 2023-24. This includes 86 Unilateral APAs (UAPAs) and 39 Bilateral APAs (BAPAs), the finance ministry said in a stateme...

India has filed 516 Advance Pricing Agreements (APA) so far, resulting in finalizing the taxation of about ₹19,000 crore of income, according to the Central Board of Direct Taxes (CBDT). The CBDT has signed 95 APA and 32 bilateral APAs in the fiscal...

The Income Tax department in India has achieved a record-high number of 95 advance pricing agreements (APA) signed in the financial year 2022-23. This marks the highest number of APA signings since the program's launch in 2012. The APA program, init...

This includes 63 Unilateral APAs (UAPAs) and 32 Bilateral APAs (BAPAs). With this, the total number of APAs since inception of the APA programme has gone up to 516, comprising 420 UAPAs and 96 BAPAs. "The BAPAs were signed as a consequence of enteri...

According to two people in the know, the government has accelerated negotiations for about 800 Advance Pricing Agreements (APAs).

The Central Board of Direct Taxes (CBDT) signed the 300th advance pricing agreement (APA) in September, 2019, an official statement said.

The nine APAs signed in the past one month pertain to sectors like telecom, healthcare, manufacturing, engineering, media and irrigation.

The international transactions covered are corporate guarantee provision, purchase of brand, availing of grading and management services and payment of royalty.

With the signing of these agreements, the total number of APAs entered into by CBDT has gone up to 219. This includes 199 unilateral APAs and 20 bilateral APAs.

The two APAs signed during September, 2017 pertain to automobile and healthcare consulting sectors.

The taxpayer has the option to rollback the APA for four preceding years, as a result of which nine years of tax certainty is provided. Since its inception,

APA Scheme endeavours to provide certainty to taxpayers in the domain of transfer pricing by specifying the methods of pricing and determining the arm's length price of international transactions in advance for the maximum of five years.

The CBDT, the apex policy making body of the income-tax department, has so far received 42 application for India-US bilateral APAs.

Transfer pricing disputes are mainly related to the calculation of profit made by multinational companies and how they have been shifted to their parent.

India had revised the three-decade old Double Taxation Avoidance agreement (DTAA) with Korea in 2015 and the amended pact came into force from September 12, 2016.

An APA is an agreement between a tax payer—mostly multinationals— and tax authority— CBDT in India—where the transfer pricing methodology is determined.

Signing of the pact is an important step towards ascertaining certainty in transfer pricing matters of MNC cases and dispute resolution, the statement noted.

US revenue authorities have decided to accept requests for bilateral advance pricing agreements (APAs) with India.

“This is a significant step towards providing a stable and predictable tax regime,” the statement added. This takes the total number of bilateral APAs signed to three.