The Central Board of Direct Taxes (CBDT), the policy-making body of the income-tax department, on Thursday said it has entered into seven unilateral advance pricing agreements (APAs) during October. APAs were introduced in 2012 by the government to give tax certainty to MNCs that agree on certain principles in the valuation of their cross-border transactions. They also provide assessees with an alternate dispute resolution mechanism with respect to transfer pricing. With the latest agreements, the total number of APAs entered into by the CBDT now stands at 184. This includes 171 unilateral and 12 bilateral APAs. In the current financial year, a total of 32 APAs (2 bilateral and 30 unilateral) have been signed till date, the CBDT said in a statement. The agreements signed last month belong to various sectors including FMCG, semi-conductor, information technology, travel and leisure, office furniture and engineering.
“The international transactions covered in these agreements include provision of IT-enabled services, provision of software development services, provision of marketing support services, provision of engineering design services, payment of interest, trading and import of components, etc,” the CBDT said. The progress of the APA scheme strengthens the government’s resolve of fostering a non-adversarial tax regime. The APA programme has been appreciated nationally and internationally for being able to address complex transfer pricing issues in a fair and transparent manner, the CBDT said.