In 2023–24, the Central Board of Direct Taxes (CBDT) signed a record 125 Advance Pricing Agreements (APAs) with taxpayers. This is a result of the government's policy to facilitate business transactions, particularly for big multinational companies that engage in a lot of cross-border business with their group entities.
From the program's inception, this is the most APA signings in any fiscal year. As to the CBDT announcement, there was a 31% surge in the number of APAs signed in FY 2023–24 as compared to the 95 APAs inked in the previous financial year.
In light of this, there have been 641 APAs in total since the APA program's start.
The signing of further accords resulted from mutual agreements with India's treaty partners, which include the US, the UK, Canada, Denmark, Japan, Australia, and Singapore.
By defining the procedures for pricing and estimating the arm's length price of foreign transactions ahead of time for a maximum of five years, the APA Scheme gives taxpayers certainty in the area of transfer pricing.
In addition, the taxpayer has the choice to reverse the APA for the four years prior, which results in nine years of tax certainty. Also, taxpayers are shielded from potential or real double taxation by signing bilateral APAs.
