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 : Insights from India's APA Programme Annual Report 2023-24, highlighting tax certainty, record signings, and benefits for multinati...
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 : 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Income Tax : In the instant case, ITAT allows the assessee to withdrawn the appeal filed for challenging the transfer pricing adjustment due to...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 APA rules provide that APA team would also include experts in economics, statistics, law or any other field as may be nominated by the DGIT (IT).Would such experts be included in each and every APA or would the need be analysed on a case to case basis?
To bring about certainty and uniformity with regard to determination of arm’s length price of the international transaction, the Finance Act, 2012 had inserted sections 92CC and 92CD in the Income Tax Act 1961 introducing the provisions of Advance Pricing Agreement (APA). The Ministry of Finance has notified an Advance Pricing Agreement Scheme (Rules 10F […]
CBDT Explains APA through a press release. Indian APA Scheme Notifies Three Types of APA unilateral, bilateral and multilateral. Press Release clarifies that the choice is on the applicant to choose a particular type of APA at the time of making the application.
Vide Notification No. 36 of 2012, in exercise of the powers conferred by sub-section (9) of section 92CC read with section 295 of the Income-tax Act, 1961 (43 of 1961), the Central Board of Direct Taxes releases Advance Pricing Agreement Scheme. The advance pricing agreement scheme shall be governed by Rules 10F to Rule 10T.
Notification No. 36/2012-Income Tax In the Income-tax Rules, 1962 (hereafter referred to as the principal rules), – (a) after rule 10E, the following rule shall be inserted, namely.- Advance Pricing Agreement Scheme- 10F. Meaning of expressions used in matters in respect of advance pricing agreement.—For the purposes of this rule and rules 10G to 10-I,-
In the part II of this series we have analyzed the proposed enactment relating Advance Pricing Agreement bringing out its benefits and issues. Also to add a broader perspective we have put forward a study of the integral features of APAs prevalent across the globe.
The APA provisions are proposed to be implemented in the Indian Income-tax Act, 1961 through the Budget recently presented before the Indian Parliament. An APA mechanism can be – Unilateral, Bilateral and Multilateral. A Unilateral APA is the one which is entered into between the tax assessee and government of a country with respect to taxability of particular cross-border transfer pricing transaction(s) in that country.
Advance Pricing Agreement is an agreement between a taxpayer and a taxing authority on an appropriate transfer pricing methodology for a set of transactions over a fixed period of time in future. The APAs offer better assurance on transfer pricing methods and are conducive in providing certainty and unanimity of approach.
