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<h1>Advance Pricing Agreements Refined: Streamlining International Tax Transactions with Clearer Guidelines and Five-Year Binding Commitments</h1> Concise Legal Summary:The document analyzes Clause 168 of the Income Tax Bill, 2025, which addresses advance pricing agreements (APAs) for international transactions. The clause largely mirrors existing legislation, providing a mechanism for pre-determining arm's length pricing between associated enterprises. Key provisions include establishing a five-year agreement period, binding effect on both taxpayers and tax authorities, and safeguards against fraudulent applications. The provision aims to enhance tax certainty, reduce litigation, and align with international transfer pricing best practices. Minor terminological updates reflect legislative modernization while maintaining the core regulatory framework for cross-border transaction pricing.