CBDT
signs record number of 125 Advance Pricing Agreements in FY24
The Central Board of Direct
Taxes (CBDT) has entered into a record 125 Advance Pricing Agreements (APAs)
with Indian taxpayers in 2023-24.
This includes 86 Unilateral
APAs (UAPAs) and 39 Bilateral APAs (BAPAs), the finance ministry said in a
statement on Tuesday.
This marks the highest ever
APA signings in any financial year since the launch of the APA programme, it
said.
The number of APAs signed in
2023-24 also represents a 31 per cent increase compared to the 95 APAs signed
during the preceding financial year.
With this, the total number
of APAs since inception of the APA programme has gone up to 641, comprising 506
UAPAs and 135 BAPAs, it said.
During 2023-24 CBDT also
signed the maximum number of BAPAs in any financial year till date, it said,
adding, the BAPAs were signed as a consequence of entering into mutual
agreements with India's treaty partners namely Australia, Canada, Denmark,
Japan, Singapore, the UK and the US.
The APA Scheme endeavours to
provide certainty to taxpayers in the domain of transfer pricing by specifying
the methods of pricing and determining the arm's length price of international
transactions in advance for a maximum of five future years.
Further, the taxpayer has
the option to rollback the APA for four preceding years, as a result of which,
tax certainty is provided for nine years.
The signing of bilateral
APAs additionally provides the taxpayers with protection from any anticipated
or actual double taxation.
The APA programme has
contributed significantly to the government of India's mission of promoting
ease of doing business, especially for multinational enterprises which have a
large number of cross-border transactions within their group entities, it said.
www.business-standard.com
dt. 17.04.2024