CBDT signs advance pricing agreement with Japanese firm

The Dollar Business Bureau

The Central Board of Direct Taxes (CBDT) has signed yet another bilateral Advance Pricing Agreement (APA) with a subsidiary of a Japanese firm.

With this new agreement, the CBDT has entered into a total of 141 APAs with various companies.

“Central Board of Direct Taxes (CBDT) signs another Bilateral Advance Pricing Agreement (APA) with a subsidiary of Japanese Company, taking the total APAs entered into by the CBDT to 141,” Ministry of Finance said in an announcement.

In the financial year 2016-17 alone, the CBDT has entered into a total of 77 unilateral and bilateral APAs. In 2015-16, it signed a total of 55 unilateral and bilateral APAs.

The total number of bilateral APAs with Japanese subsidiaries has now reached five, all with rollback provisions.

The CBDT has signed four APAs out of these five agreements in the current financial year, all with Japanese trading companies (Sogo Soshas).

“Certainty in tax treatment for Sogo Soshas has been a long standing demand of the Japanese industry. The bilateral signing of APAs in this sector provides tax certainty up to nine years in each of these cases,” the statement said.

An advance pricing agreement (APA) is a multilateral or bilateral agreement between a tax authority and a taxpayer on transfer pricing methodology (TPM), transactions issued for multiple years.

The government envisages resolving more than 100 transfer pricing disputes by signing APAs with multinationals. The CBDT has set its eyes on more than 175 banking, IT, ITES and pharma multinationals to ink APAs.