CBDT, Netherlands sign two APAs pertaining to electronics, technology sectors

The Central Board of Direct Taxes (CBDT) has entered into two bilateral Advance Pricing Agreements (APAs) during the month of November, 2017; the first ever Bilateral APAs with The Netherlands; pertaining to the electronics and technology sectors of the economy.

With the signing of these agreements, the total number of APAs entered into by the CBDT stands at 186, including 171 unilateral APAs and 15 bilateral APAs.

The international transactions covered in these agreements include distribution, provision of marketing support services, provision of business support services, and so on.

The APA provisions were introduced in the Income-tax Act 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.