CBDT signs 5 Unilateral APAs with Indian taxpayers

The Dollar Business Bureau 

The Central Board of Direct Taxes (CBDT) on Thursday signed five Unilateral Advance Pricing Agreements (APAs) with Indian taxpayers, making the total number of APAs to 108.

“The Central Board of Direct Taxes (CBDT), Department of Revenue, Ministry of Finance entered into five (5) Unilateral Advance Pricing Agreements (APAs) on October 27, 2016 with Indian taxpayers,” said an official release.

The APAs cover a number of foreign transactions, such as purchase of raw materials, sale of finished goods, IT enabled services, software development services, interest payment and exports.

The agreements are related to various industrial sectors such as IT services manufacturing, etc. These also provide certainty for 5 years to the taxpayers with regard to the covered foreign transactions.

With the signing of these five APAs, the total number of agreements signed till now has reached to 108 that include 104 unilateral and four bilateral APAs signed since 2013-14. Out of these, 44 agreements have been completed in just seven months of the current fiscal, the release said.

The APA scheme was initiated in 2012 in the Income Tax Act and in 2014, the provisions for Rollback were introduced, it added.

The Scheme is aimed to give certainty to the taxpayers in the area of transfer pricing by laying down the pricing methods and calculating the arm’s length price of foreign transactions beforehand for a maximum of five-year period.

In addition, there is an option for taxpayers to roll-back the APA for preceding four years. Since its commencement, the Scheme has attracted huge interest among the multi-national enterprises and over 700 applications both unilateral and bilateral have been submitted in only four years.