Advance Pricing Agreement

Advance Pricing Agreements – Latest Developments

Income Tax - Advance Pricing Agreements What is an Advance Pricing Agreement (APAs)? According to Indian Tax Laws, it is an agreement between the Central Board of Direct Taxes (CBDT) and any person, which determines, in advance, the arm’s length price or specifies the manner of the determination of arm’s length price (or both), in relation to an [...

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All about Advance Pricing Agreement (APA)

Income Tax - The CBDT, with Central Government’s approval, enter into APA with the applicant assesse determining the ALP and/or methods for determining ALP which is to be followed notwithstanding anything contained in section 92C / 92CA of the Act...

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Advance Pricing Agreements – International Taxation Latest Developments

Income Tax - According to Indian Tax Laws, it is an agreement between CBDT and any person, which determines, in advance, the arm’s length price or specifies the manner of the determination of arm’s length price (or both), in relation to an international transaction. ...

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Concept of Advance Pricing Agreements

Income Tax - Transfer Pricing, a concept generally used in case of an International as well as Domestic Transactions between interrelated or associated enterprises. These provisions have been introduced to check revenue erosion from India by Multinational companies....

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Roll back provision in Advance Pricing Agreement Scheme

Income Tax - Section 92CC of the Act provides for Advance Pricing Agreement (APA). It empowers the Central Board of Direct Taxes, with the approval of the Central Government, to enter into an APA with any person for determining the Arm’s Length Price (ALP) or specifying the manner in which ALP is to be determined in relation to an international tran...

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APA rollback rules should be made applicable to similar nature of transactions with different AEs: ICAI

Income Tax - The CBDT introduced the rollback rules under the APA program on 14 March 2015. There were some ambiguities about the implementation of the rollback rules, and therefore, CBDT issued Frequently Asked Questions (FAQs) clarifying certain issues....

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CBDT enters 3 more APAs during the month of December, 2017

Income Tax - CBDT has entered into three more Advance Pricing Agreements (APAs) during the month of December, 2017. While two of the Agreements are Unilateral, one is a Bilateral with the United Kingdom. With the signing of these Agreements, the total number of APAs entered into by the CBDT has gone up to 189. This includes 173 Unilateral APAs and 16 ...

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CBDT signs two Indian APAs with Netherlands in November, 2017

Income Tax - CBDT has entered into 2 Bilateral Advance Pricing Agreements (APAs) during the month of November, 2017. These Agreements are the first ever Bilateral APAs with The Netherlands. With the signing of these Agreements, the total number of APAs entered into by the CBDT has gone up to 186. This includes 171 Unilateral APAs and 15 Bilateral APAs...

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CBDT signs seven Unilateral APAs in October, 2017

Income Tax - The Central Board of Direct Taxes (CBDT) has entered into 7 more Advance Pricing Agreements (APAs) during the month of October, 2017. All these Agreements are Unilateral....

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Indian APA regime moves forward with signing of two more APAs

Income Tax - The Central Board of Direct Taxes (CBDT) has entered into 2 Unilateral Advance Pricing Agreements (UAPAs) with Indian Taxpayers during September, 2017. With the signing of these 2 Agreements, the total number of APAs entered into by CBDT till date has reached 177. This includes 164 Unilateral APAs and 13 Bilateral APAs. In the current fin...

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CBDT revises format of Form No. 3CED- Application for Advance Pricing Agreement

Notification No. 53/2017-Income Tax / S.O. 1927(E) - (16/06/2017) - S.O. 1927(E). In exercise of the powers conferred by section 295 read with sub-section (9) of section 92CC of the Income-tax Act, 1961 (43 of 1961), the Central Board of Direct Taxes hereby makes the following rules further to amend the Income-tax Rules, 1962, namely...

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Signing of Bilateral Advance Pricing Agreement by CBDT

NA - (04/08/2016) - The Central Board of Direct Taxes (CBDT) entered into a Bilateral Advance Pricing Agreement (APA) on 2nd August, 2016 with the Indian subsidiary of a Japanese trading company. This is the first Bilateral Advance Pricing agreement with a Japanese company having a Rollback provision in it. Overall, it...

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CBDT signs 11 more unilateral Advance Pricing Agreements

NA - (29/03/2016) - 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. 50 of these agreements have been signed in the current financial year. The agreements cover a range of international transactions, including cor...

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FAQs: Rollback Provisions of Advance Pricing Agreement Scheme

Circular No. 10/2015-Income Tax - (10/06/2015) - CIRCULAR NO. 10/2015 The Advance Pricing Agreement provisions were introduced in 2012 through insertion of sections 92CC and 92CD in the Income-tax Act, 1961 by the Finance Act, 2012. Subsequently, the Advance Pricing Agreement Scheme was notified vide S.O. 2005 (E), dated 30/8/2012, thereby inserti...

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Application for Roll Back of APA can be made upto to 30.06.2015

NA - (31/03/2015) - The rules relating to Roll Back of an Advance Pricing Agreement (APA) have been notified through notification no. S.O. 758 (E) dated 14th March, 2015. As per sub-rule (5) of the newly prescribed rule 10MA, where an application for entering into an advance pricing agreement has been filed prior to 1....

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Recent Posts in "Advance Pricing Agreement"

APA rollback rules should be made applicable to similar nature of transactions with different AEs: ICAI

The CBDT introduced the rollback rules under the APA program on 14 March 2015. There were some ambiguities about the implementation of the rollback rules, and therefore, CBDT issued Frequently Asked Questions (FAQs) clarifying certain issues....

Read More
Posted Under: Income Tax |

CBDT enters 3 more APAs during the month of December, 2017

CBDT has entered into three more Advance Pricing Agreements (APAs) during the month of December, 2017. While two of the Agreements are Unilateral, one is a Bilateral with the United Kingdom. With the signing of these Agreements, the total number of APAs entered into by the CBDT has gone up to 189. This includes 173 Unilateral APAs and 16 ...

Read More
Posted Under: Income Tax |

CBDT signs two Indian APAs with Netherlands in November, 2017

CBDT has entered into 2 Bilateral Advance Pricing Agreements (APAs) during the month of November, 2017. These Agreements are the first ever Bilateral APAs with The Netherlands. With the signing of these Agreements, the total number of APAs entered into by the CBDT has gone up to 186. This includes 171 Unilateral APAs and 15 Bilateral APAs...

Read More
Posted Under: Income Tax |

CBDT signs seven Unilateral APAs in October, 2017

The Central Board of Direct Taxes (CBDT) has entered into 7 more Advance Pricing Agreements (APAs) during the month of October, 2017. All these Agreements are Unilateral....

Read More
Posted Under: Income Tax |

Indian APA regime moves forward with signing of two more APAs

The Central Board of Direct Taxes (CBDT) has entered into 2 Unilateral Advance Pricing Agreements (UAPAs) with Indian Taxpayers during September, 2017. With the signing of these 2 Agreements, the total number of APAs entered into by CBDT till date has reached 177. This includes 164 Unilateral APAs and 13 Bilateral APAs. In the current fin...

Read More
Posted Under: Income Tax |

CBDT Signs four APAs in August, 2017

CBDT has entered into 4 more Advance Pricing Agreements (APAs) during August, 2017. Out of these 4 Agreements, 3 are Unilateral and 1 is a Bilateral. The Bilateral APA is for international transactions between an Indian company and a UK-based company....

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Posted Under: Income Tax |

Advance Pricing Agreements – Latest Developments

Advance Pricing Agreements What is an Advance Pricing Agreement (APAs)? According to Indian Tax Laws, it is an agreement between the Central Board of Direct Taxes (CBDT) and any person, which determines, in advance, the arm’s length price or specifies the manner of the determination of arm’s length price (or both), in relation to an [...

Read More
Posted Under: Income Tax |

CBDT signs nine APAs in July, 2017

Central Board of Direct Taxes (CBDT) entered into nine Unilateral Advance Pricing Agreements (UAPAs) with Indian taxpayers in the month of July, 2017. Some of the UAPAs signed had rollback provisions also....

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Posted Under: Income Tax |

All about Advance Pricing Agreement (APA)

The CBDT, with Central Government’s approval, enter into APA with the applicant assesse determining the ALP and/or methods for determining ALP which is to be followed notwithstanding anything contained in section 92C / 92CA of the Act...

Read More
Posted Under: Income Tax |

Advance Pricing Agreements – International Taxation Latest Developments

According to Indian Tax Laws, it is an agreement between CBDT and any person, which determines, in advance, the arm’s length price or specifies the manner of the determination of arm’s length price (or both), in relation to an international transaction. ...

Read More
Posted Under: Income Tax |
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