CBDT signs record 174 APAs in FY25, including India's 1st multilateral APA

The Central Board of Direct Taxes (CBDT) has signed a record 174 Advance Pricing Agreements (APAs) with Indian taxpayers in FY25, marking the highest number finalised in a single financial year since the programme’s inception, the tax department said on Monday.

 

An APA helps taxpayers and tax authorities agree on how to price transactions between related companies in different countries. It was introduced in the 2012 Finance Act and took effect on July 1, 2012. APAs reduce tax disputes by providing certainty. The CBDT can make these agreements for up to five years.

 

The agreements include unilateral APAs (UAPAs), bilateral APAs (BAPAs), and the first-ever multilateral APA (MAPA). With this, the total number of APAs signed since the programme began has reached 815, comprising 615 UAPAs, 199 BAPAs, and 1 MAPA, as per the release.

 

"This marks the highest number of APAs signed in a single financial year since the programme's launch. Of the 174 APAs signed, 65 were BAPAs, the highest number of BAPAs finalised in any year so far. These were a result of mutual agreements with India’s treaty partners, including Australia, Japan, South Korea, the Netherlands, New Zealand, Singapore, the UK, and the US," the CBDT said.

 

CBDT had signed 125 APAs in FY24 and 95 in FY23. Notably, this year also saw the signing of India’s first-ever MAPA. Additionally, on March 27, 2025, a record 34 APAs were signed on a single day, the release stated.

 

"The APA programme has significantly contributed to the Government of India’s mission to enhance ease of doing business, particularly for multinational enterprises engaged in extensive cross-border transactions. CBDT recognises the collaborative spirit of taxpayers and values their role as key stakeholders in the successful implementation of the APA programme," CBDT added.