Conversion of unilateral APA into bilateral APA requires a bilateral competent authority request and treaty-based agreement. Conversion of a unilateral APA into a bilateral APA requires the applicant or its associated enterprise to request conversion with the other jurisdiction's competent authority; DGIT (Intl. Taxation) forwards the bilateral request to India's competent authority, which permits conversion only if the tax treaty contains a provision consistent with the OECD Model Article 9 principle and the other country maintains an APA program, after which the application is processed as a bilateral APA.