Advance Pricing Agreement (APA) Programme of India - Annual Report (2016-17)

Advance Pricing Agreement programme provides transfer pricing certainty; 152 APAs signed, TNMM predominant, average processing 29-39 months. The APA Programme, backed by Sections 92CC-92CD and Rules 10F-10T, enables unilateral, bilateral and multilateral agreements to determine ALP or its computation, includes rollback for up to four prior years, and is processed by APA teams under Pr. CCIT and CBDT FT&TR Divisions; to 31 March 2017 India received 815 applications and concluded 152 APAs (141 unilateral, 11 bilateral), with TNMM the predominant method and average processing times of about 29 months (unilateral) and 39 months (bilateral).