New Delhi, February 7: Today the Central Board of Direct Taxes CBDT announced that it has signed four unilateral Advance Pricing Agreements APAs on Monday which concerns to the manufacturing, financial and information technology sectors. The CBDT, Revenue department and the Ministry of Finance has entered into APAs.
This agreement has paved the way into the manufacturing and financial sectors of economy. The international transactions covered in these agreements include contract manufacturing IT enabled services and software development services.
The total number of APAs entered into by the CBDT has now reached to 130.This includes eight bilateral APAs and 122 Unilateral APAs. In the current financial year, a total of 66 APAs (five bilateral APAs and 61 unilateral APAs) have already been entered into. The CBDT expects more APAs to be concluded and signed before the end of the current fiscal.
The APA scheme was introduced in the Income-tax Act in 2012 and the “rollback” provisions were introduced in 2014. The scheme aspires to provide certainty to taxpayers in the domain of transfer pricing by specifying the methods of pricing and determining the prices of international transactions in advance.
The APA scheme has shown a lot of interest from taxpayers and that has resulted in more than 700 applications (both unilateral and bilateral) being filed so far in about five years. The progress of the APA Scheme strengthens the government’s resolve of fostering a non-adversarial tax regime. The Indian APA program has been appreciated nationally and internationally for being able to address complex transfer pricing issues in a fair and transparent manner.