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of <h1>Convert Unilateral APA to Bilateral APA Before Draft Sent to Board, Requires Requests to Both Countries' Authorities</h1> A unilateral Advance Pricing Agreement (APA) can be converted into a bilateral APA before the draft agreement is sent by the Director General of Income Tax (International Taxation) to the Board. To initiate this conversion, the applicant or its associated enterprise must submit a similar request to the competent authority of the other country involved. The Director General will forward the bilateral request to India's competent authority. Approval depends on the presence of relevant provisions in the tax treaty between India and the other country, as per OECD Model Article 9(2), and the existence of an APA program in the other country. If approved, the application proceeds as a bilateral APA.
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