CBDT achieves important milestone of 200 APAs

The Central Board of Direct Taxes (CBDT) on Thursday announced that it has entered into seven more Advance Pricing Agreements (APAs) during February, 2018.

All seven agreements are unilateral APAs.

With the signing of these agreements, the CBDT has crossed the important milestone of having signed 200 APAs.

The seven APAs signed in February pertain to pharmaceuticals, automobiles, financial and the food and beverages sectors.

The international transactions covered in these agreements include manufacturing, provision of software development services, provision of IT enabled services, payment of royalty, provision of contract R&D services, provision of marketing support services, distribution, Advertising, Marketing and Promotion (AMP) expenses, provision of engineering design support services, provision of sourcing support services, and payment of interest, among others.

The total number of APAs entered into by the CBDT till date has gone up to 203. This includes 185 unilateral APAs and 18 bilateral APAs.

In the current financial year, the CBDT has entered into 51 APAs, so far (44 unilateral APAs and 7 bilateral APAs).

The APA provisions were introduced in the Income-tax Act, 1961 in 2012 and the "Rollback" provisions were introduced in 2014.

The APA scheme endeavours 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.

The progress of the APA scheme strengthens the government's resolve of fostering a non-adversarial tax regime.

The Indian APA programme has been appreciated nationally and internationally for being able to address complex transfer pricing issues in a fair and transparent manner.

It has contributed significantly towards improving the 'Ease of doing business' in India.