March 1, 2018
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Advance Pricing Agreements: CBDT reaches milestone, expanding transfer pricing certainty and non adversarial compliance for taxpayers nationwide.
The CBDT signed seven additional APAs, all Unilateral, raising the total to 203 APAs (185 Unilateral and 18 Bilateral). The recent agreements span Pharmaceuticals, Automobiles, Financial and Food & Beverages sectors and cover international transactions including manufacturing, software and IT services, royalties, contract R&D, marketing support, distribution, AMP expenses, engineering design and sourcing support, and interest. The APA scheme, introduced in the Income tax Act in 2012 with rollback provisions added in 2014, is intended to provide transfer pricing certainty by specifying pricing methods in advance and to promote a non adversarial tax regime.