An APA is a agreement between a taxpayer and at least one tax authority concerning the TP method functional to a taxpayer’s inter-company transactions and will usually cover multiple years.
Income Tax : Learn about Advance Pricing Agreements (APAs) and Mutual Agreement Procedures (MAPs) in international taxation. Understand their e...
Income Tax : Explore the story of a multinational companys journey with Advance Pricing Agreements (APAs), ensuring compliance, transparency, a...
Income Tax : Learn about the special features of Advance Pricing Agreements (APAs) in India, annual compliances, revision, cancellation, and mo...
Income Tax : In India, the underlying idea behind the scheme of APA is to make tax administration better and efficient by encouraging taxpayers...
Income Tax : The APA determines the transfer pricing methodology for pricing an enterprises’ future international transactions or certain spe...
Income Tax : CBDT achieves a record 125 APAs in FY 2023-24, marking a 31% increase. Learn about the significance and impact on transfer pricing...
Income Tax : Dive deep into Annual Report of APA Programme in India for years 2019-2022. Explore CBDT's efforts, accomplishments, and challenge...
Income Tax : CBDT has entered into a record 95 Advance Pricing Agreements (APAs) in FY 2022-23 with Indian taxpayers. This includes 63 Unilater...
Income Tax : The Advance Pricing Agreement (APA) programme in India was introduced more than seven years ago. It is currently in its 7th annual...
Income Tax : The Central Board of Direct Taxes (CBDT) has signed the 300th Advance Pricing Agreement (APA) during the month of September, 2019....
Income Tax : ITAT held that advance pricing agreement APA is applicable only for specified time span not exceeding five consecutive previous ye...
Income Tax : In the instant case, ITAT allows the assessee to withdrawn the appeal filed for challenging the transfer pricing adjustment due to...
Income Tax : CBDT has entered into 26 APAs in the first 5 months of the current financial year (April to August, 2019). With the signing of the...
Income Tax : 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, ...
Income Tax : Central Board of Direct Taxes signed 11 unilateral APAs on 28th March, 2016. With this signing, India has entered into 59 bilatera...
Income Tax : CIRCULAR NO. 10/2015 The Advance Pricing Agreement provisions were introduced in 2012 through insertion of sections 92CC and 92CD ...
Income Tax : Notification No. 23/2015 - Income Tax In exercise of the powers conferred by sub-sections (9) and(9A) of section 92CC read with s...
The Advance Pricing Agreement program has been a key dispute prevention mechanism in the Indian direct taxes set-up. There are three kinds of Advance Pricing Agreements – unilateral, bilateral and multilateral. Credibility of a tax administration depends to a large extent upon the efficacy of its dispute resolution mechanism. Advance Pricing Agreements have played a […]
Over the last few months, we have witnessed the profound impact of the COVID-19 outbreak on our day to day lives. The outbreak has led to imposition of lockdown across the globe which in turn restricted global economic activity. Economies and markets have been hit hard by the outbreak which resulted in businesses making desperate […]
Evolution of advance pricing agreement concept in India The transfer pricing framework in India has been introduced through Finance Act, 2001 which requires determination of Arm Length Price (ALP) for all the international transaction between associated enterprises. Since then, the ALP determination has been the matter of long aged and numerous disputes between department of […]
Budget 2020:Amendment for providing attribution of profit to Permanent Establishment in Safe Harbour Rules under section 92CB and in Advance Pricing Agreement under section 92CC Section 92CB of the Act empowers the Central Board of Direct Taxes (Board) for making safe harbour rules (SHR) to which the determination of the arm’s length price (ALP) under […]
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.
This article is about Advance Pricing Agreements (APA) provisions. Mainly it will cover the basic meaning of Advance Pricing Agreement, types of Advance Pricing Agreement, objectives of Advance Pricing Agreement and number of Advance Pricing Agreement signed by India. What is an Advance Pricing Agreement (APAs)? According to Indian Tax Laws, it is an agreement […]
The Advance Pricing Agreement (APA) programme in India was introduced more than seven years ago. It is currently in its 7th annual cycle of examination and processing of applications. The CBDT is very happy about the fact that this programme has been accepted well by taxpayers and tax consultants. We are very proud of the results generated and the positive impact that the programme has had on the tax environment in India.
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 […]
CBDT has entered into 26 APAs in the first 5 months of the current financial year (April to August, 2019). With the signing of these APAs, the total number of APAs entered into by the CBDT as of now stand at 297, which includes 32 BAPAs.
Executive Summary A separate code on transfer pricing under sections 92 to 92F of the Income Tax Act, 1961 (hereafter, the ITA) covering intra-group cross-border transactions became applicable from 1 April 2001. The regulations are based on the arm’s length principle and provided for determination of arm’s length price of international transactions between associated enterprises. The Rules 10A to 10 E of the Income Tax Rules, 1962 (hereafter, the Rules) deals with procedural aspects regarding the implementation of transfer pricing law.
