Recently, the Central Board of Direct Taxes (CBDT) signed the first ever substantive revision to an India-U.K. Bilateral advance pricing agreement (APA) due to certain changes in the way a particular transaction was being conducted. The changes were the direct result of a commercial need for the taxpayer’s business that developed during the term of the APA.
The Indian and the U.K. Competent Authority Offices appreciated the fact that this change became imperative to implement from a wider MNC group perspective. The Competent Authorities of both countries confirmed a willingness to understand the business and commercial realities of the taxpayer’s business and agreed with the requirement and rationale of the relevant change in the taxpayer’s business.
