On 27 November 2017, the Indian Government has announced that the MAP for transfer pricing disputes and the bilateral advance pricing agreement (APA) process would be available to taxpayers even where Article 9(2) or the equivalent is not present in the double taxation avoidance agreement (DTAA) with the taxpayer’s jurisdiction.
The clarification would likely encourage more mutual agreement procedures (MAP) and provide consistency in the country’s direct tax regime, experts said.
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