CBDT signed 95 Advance Pricing Agreements in FY 2022-23

Press Release, dated 31-03-2023

The CBDT entered a record 95 Advance Pricing Agreements (APAs) in FY 2022-23 with Indian taxpayers. This is the highest-ever APA signings in any financial year since the board’s launch of the APA programme. APA Scheme endeavours to provide taxpayers with transfer pricing certainty by specifying the pricing methods and determining the ALP of international transactions in advance for a maximum of future years.

Further, the taxpayer has the option to roll back the APA for four preceding years, as a result of which tax certainty is provided for nine years. The signing of bilateral APAs also protects taxpayers from any anticipated or actual double taxation.

The APA programme has contributed significantly to the Government of India’s mission of promoting ease of doing business, especially for Multi-National Enterprises (MNEs) which have a large number of cross-border transactions within their group entities.

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