The Central Board of Direct Taxes on Friday singed five unilateral advance pricing agreements (APAs) with Indian taxpayers as it looks to reduce litigation by providing certainty in transfer pricing. “One of these agreements has a rollback provision in it. With these signings, the total number of APAs entered into by the CBDT has reached 103,” the Finance Ministry said in a statement.
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“The 5 APAs signed today pertain to diverse sectors, i.e., information technology, sourcing services and investment advisory services,” it added.
The statement further said 103 APAs signed so far include 4 bilateral APAs and 99 unilateral APAs.
“A total of 39 APAs have already been concluded in six months of the current Financial Year,” it said.
CBDT expects more APAs to be concluded and signed in the near future, the statement said, adding that the progress of the APA scheme strengthens the government’s commitment to foster a non-adversarial tax regime.
The APA scheme was introduced in the Income-tax Act in 2012 and the rollback provisions were introduced in 2014.
The 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 five years.
Further, the taxpayer has the option to rollback the APA for four preceding years.
Since its inception, the APA scheme has attracted tremendous interest among Multi National Enterprises (MNEs) and more than 700 applications (both unilateral and bilateral) have been filed in just four years, the statement said.