TaxTMI 
TaxTMI 
TaxTMI 
Government signs 11 unilateral Advance Pricing Agreements (APAs)
X X X X Extracts X X X X
X X X X Extracts X X X X
....overnment signs 11 unilateral Advance Pricing Agreements (APAs) <br>News and Press Release<br>Dated:- 30-3-2016<br><BR>The Central Board of Direct Taxes signed 11 unilateral APAs on 28th March, 2016. With this signing, India has entered into 59 bilateral and/or unilateral APAs. The Advance Pricing Agreement (APA) programme was introduced by the Finance Act, 2012 to provide a predictable and non-ad....
X X X X Extracts X X X X
X X X X Extracts X X X X
....versarial tax regime and to reduce litigation in the Indian transfer pricing regime. 50 of these agreements have been signed in the current financial year. The agreements cover a range of international transactions, including corporate guarantees, royalty, software development services, IT enabled services and trading. The agreements pertain to different industrial sectors like telecom, media, aut....
X X X X Extracts X X X X
X X X X Extracts X X X X
....omobiles, IT services, etc. Some of the agreements have rollback provisions and provide certainty to the taxpayers for 9 years with regard to the covered international transactions. Rollback provisions in APAs were introduced in the July 2014 Budget to provide certainty on the pricing of international transactions for 4 years (rollback years) preceding the first year from which APA becomes applic....
X X X X Extracts X X X X
X X X X Extracts X X X X
....able. With the notification of Rollback rules in March 2015, the taxpayer has been provided the option to choose certainty in transfer pricing matters with the Government for a total of nine years (5 future years and 4 prior years). Since the notification of the APA scheme on 30.08.2012, approximately 580 applications for APAs have been received and about half of these contain a request for the R....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ollback provisions. The number of applications is indicative of the wide international and national appreciation of the India's APA programme's ability to address complex transfer pricing issues in a fair and transparent manner.<BR> News - Press release - PIB....