The Central Board of Direct Taxes (CBDT) entered into seven Unilateral Advance Pricing Agreements (APAs) today with Indian taxpayers including a few agreements with a rollback provision.
The APA Scheme was introduced in the Income-tax Act in 2012 and the rollback provisions were introduced in 2014.
The scheme endeavors to provide certainty to taxpayers in the domain of transfer pricing by specifying the methods of pricing and setting the prices of international transactions in advance. Since its inception, the APA scheme has attracted tremendous interest and that has resulted in more than 700 applications (both unilateral and bilateral) having been filed in just four years.
The seven APAs signed pertain to various sectors of the economy like banking, Information Technology and Automotives.
The international transactions covered in these agreements include software development Services, IT enabled Services (BPOs), Engineering Design Services and Administrative and Business Support Services. The total number of APAs entered into by the CBDT has reached 77.
This includes three bilateral APAs and 74 Unilateral APAs. In the current financial year, a total of 13 Unilateral APAs have been entered into so far.
The progress of the APA Scheme strengthens the Government’s mission of fostering a non-adversarial tax regime. The CBDT expects more APAs to be concluded and signed in the near future.