September 4, 2019
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Advance Pricing Agreements strengthen non-adversarial transfer pricing framework, enhancing certainty for cross-border transactions across multiple industry sectors.
The Central Board of Direct Taxes has executed multiple Advance Pricing Agreements, both bilateral and unilateral, covering specified international transactions-such as contract manufacturing, software and back office services, royalties, trading, intra group services and financing-across diverse industry sectors, using APAs to pre determine transfer pricing methodologies and promote a non adversarial, transparent framework that reduces disputes and provides tax certainty for cross border operations.