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Advance Pricing Agreement

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.

Latest Articles


Comparative analysis of Mutual agreement Procedure & Advance pricing agreement

Income Tax : Learn about Advance Pricing Agreements (APAs) and Mutual Agreement Procedures (MAPs) in international taxation. Understand their e...

March 16, 2024 1470 Views 0 comment Print

Advance Pricing agreement as a story

Income Tax : Explore the story of a multinational companys journey with Advance Pricing Agreements (APAs), ensuring compliance, transparency, a...

May 21, 2023 1554 Views 0 comment Print

51 FAQs on Advance Pricing Agreements (APAs) in India

Income Tax : Learn about the special features of Advance Pricing Agreements (APAs) in India, annual compliances, revision, cancellation, and mo...

November 2, 2022 6117 Views 0 comment Print

Advance pricing agreements – a fresh start in India?

Income Tax : In India, the underlying idea behind the scheme of APA is to make tax administration better and efficient by encouraging taxpayers...

May 11, 2022 2325 Views 1 comment Print

Reducing Transfer Pricing Litigation via Advance Pricing Agreements

Income Tax : The APA determines the transfer pricing methodology for pricing an enterprises’ future international transactions or certain spe...

May 11, 2022 2274 Views 0 comment Print


Latest News


Advance Pricing Agreement (APA) Programme Annual Report 2023-24

Income Tax : Insights from India's APA Programme Annual Report 2023-24, highlighting tax certainty, record signings, and benefits for multinati...

January 14, 2025 357 Views 0 comment Print

CBDT signs record 125 Advance Pricing Agreements (APAs) in FY 2023-24

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...

April 17, 2024 1416 Views 0 comment Print

Annual Report on APA Programme by CBDT: Highlights & Insights (2019-22)

Income Tax : Dive deep into Annual Report of APA Programme in India for years 2019-2022. Explore CBDT's efforts, accomplishments, and challenge...

September 1, 2023 954 Views 0 comment Print

CBDT Signs 95 Advance Pricing Agreements in FY 2022-23

Income Tax : CBDT has entered into a record 95 Advance Pricing Agreements (APAs) in FY 2022-23 with Indian taxpayers. This includes 63 Unilater...

April 1, 2023 1542 Views 0 comment Print

Advance Pricing Agreement (APA) -Programme of India- Annual Report (2018-19)

Income Tax : The Advance Pricing Agreement (APA) programme in India was introduced more than seven years ago. It is currently in its 7th annual...

December 1, 2019 6372 Views 0 comment Print


Latest Judiciary


Advance pricing agreement is applicable only to specified assessment years

Income Tax : ITAT held that advance pricing agreement APA is applicable only for specified time span not exceeding five consecutive previous ye...

November 7, 2022 915 Views 0 comment Print

ITAT allows to withdrawn appeal challenging TP Adjustment due to APA

Income Tax : In the instant case, ITAT allows the assessee to withdrawn the appeal filed for challenging the transfer pricing adjustment due to...

September 9, 2020 651 Views 0 comment Print


Latest Notifications


CBDT enters into 26APAs during current Financial Year

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...

September 4, 2019 1068 Views 0 comment Print

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

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, ...

June 16, 2017 4596 Views 0 comment Print

CBDT signs 11 more unilateral Advance Pricing Agreements

Income Tax : Central Board of Direct Taxes signed 11 unilateral APAs on 28th March, 2016. With this signing, India has entered into 59 bilatera...

March 29, 2016 1189 Views 0 comment Print

FAQs: Rollback Provisions of Advance Pricing Agreement Scheme

Income Tax : CIRCULAR NO. 10/2015 The Advance Pricing Agreement provisions were introduced in 2012 through insertion of sections 92CC and 92CD ...

June 10, 2015 5299 Views 0 comment Print

Rules & forms for rollback of Advance Pricing Agreement

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...

March 14, 2015 9559 Views 0 comment Print


Advance Pricing Agreement Programme in India

July 28, 2019 6171 Views 0 comment Print

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.

Power of AO in respect of modified return of income filed as per APA

July 9, 2019 10950 Views 0 comment Print

Budget 2019: Clarification with regard to power of Assessing Officer in respect of modified return of income filed in pursuance to signing of Advance Pricing Agreement (APA) Section 92CC of the Act empowers the Central Board of Direct Taxes (CBDT) to enter into an APA, with the approval of the Central Government, with any person […]

CBDT signs 18 Advance Pricing Agreement in March, 2019

April 3, 2019 684 Views 0 comment Print

CBDT has entered into 18 APAs in the month of March 2019, which includes 03 Bilateral APAs (BAPAs). With the signing of these APAs, the total number of APAs entered into by the CBDT in the year 2018-19 stands at 52

Total APAs entered into by CBDT increases to 244

November 2, 2018 540 Views 0 comment Print

Total number of APAs entered into by the CBDT has gone up to 244, which includes 220 UAPAs and 24 BAPAs. It is noteworthy that one of the UAPAs signed in October is a renewal application and the same has been concluded in a time span of only 7 months.

Annual Report on India’s Advance Pricing Agreement (APA) Programme– 2017-18

August 31, 2018 1557 Views 0 comment Print

The Advance Pricing Agreement (APA) Programme in India is six years old now and has been heralded as a success. The CBDT is extremely proud of this Programme and its achievements. The Programme has been successful in winning the confidence of taxpayers by providing them with an alternate dispute resolution mechanism in respect of transfer […]

CBDT signs nine UAPAs in July, 2018

August 2, 2018 546 Views 0 comment Print

CBDT has entered into nine more Unilateral Advance Pricing Agreements (UAPAs) during the month of July, 2018. With the signing of these Agreements, the total number of APAs entered into by the CBDT has gone up to 232, which includes 20 Bilateral Advance Pricing Agreements (BAPAs).

CBDT signs three UAPAs in May and June, 2018

July 4, 2018 606 Views 0 comment Print

The Central Board of Direct Taxes (CBDT) has entered into three Unilateral Advance Pricing Agreements (UAPA) during the past couple of months. With the signing of these Agreements, the total number of APAs entered into by the CBDT has gone up to 223, which inter alia include 20 Bilateral APAs.

CBDT achieves another milestone by signing its 200th UAPA in April, 2018

May 4, 2018 675 Views 0 comment Print

CBDT has entered into one Unilateral Advance Pricing Agreement (UAPA) during April, 2018. With signing of this Agreement, CBDT has achieved another milestone of having signed its 200th UAPA.

CBDT signs 16 APAs in march 2018

April 3, 2018 993 Views 0 comment Print

Indian Advance Pricing Agreement regime moves forward with the signing of 16 APAs by CBDT in March, 2018 The Central Board of Direct Taxes (CBDT) entered into 14 Unilateral Advance Pricing Agreements (UAPA) and 2 Bilateral Advance Pricing Agreements (BAPA) during the month of March, 2018. The 2 bilateral APAs have been entered into with […]

CBDT achieves important milestone of 200 APAs

March 1, 2018 951 Views 0 comment Print

The Central Board of Direct Taxes (CBDT) entered into seven more Advance Pricing Agreements (APAs) during the month of February, 2018. All the seven are Unilateral APAs. With the signing of these Agreements, CBDT has crossed an important milestone of having signed 200 APAs. The total number of APAs entered into by the CBDT till […]

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