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        News and Press Release

        CBDT inks the 300th Advance Pricing Agreement

        October 1, 2019

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        The Central Board of Direct Taxes (CBDT) has signed the 300th Advance Pricing Agreement (APA) during the month of September, 2019. This is a significant landmark of India’s APA Programme, which is currently in its seventh year.

        Three APAs were entered into in September, 2019 (2 Unilateral and 1 Bilateral APA), which has taken the total number of APAs signed by CBDT to 300. During the ongoing fiscal, the total number of APAs entered into has gone up to 29 (27 Unilateral and 2 Bilateral APAs). The Bilateral APA signed in September, 2019 pertains to United Kingdom.

        The APAs entered into during September, 2019 pertain to various sectors of the economy like retail, garments, and consumer foods. The international transactions covered in these agreements, inter alia, include provision of software development services, contract manufacturing, provision of IT enabled Services and provision of Support Services.

        The APA Scheme continues to make good progress in providing tax certainty to MNEs. It reflects the Government’s commitment towards fostering a non-adversarial tax regime.

        Advance Pricing Agreements provide tax certainty to multinational enterprises, strengthening a non-adversarial transfer pricing framework. The Central Board of Direct Taxes has executed the Advance Pricing Agreement (APA) mechanism to its 300th signed agreement, including two unilateral APAs and one bilateral APA with the United Kingdom; APAs during the period cover sectors such as retail, garments and consumer foods and address international transactions including software development services, contract manufacturing, IT enabled services and support services to provide tax certainty to multinational enterprises and reduce transfer pricing disputes.
                          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                            Provisions expressly mentioned in the judgment/order text.

                                Advance Pricing Agreements provide tax certainty to multinational enterprises, strengthening a non-adversarial transfer pricing framework.

                                The Central Board of Direct Taxes has executed the Advance Pricing Agreement (APA) mechanism to its 300th signed agreement, including two unilateral APAs and one bilateral APA with the United Kingdom; APAs during the period cover sectors such as retail, garments and consumer foods and address international transactions including software development services, contract manufacturing, IT enabled services and support services to provide tax certainty to multinational enterprises and reduce transfer pricing disputes.





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