The Indian Central Board of Direct Taxes (CBDT) announced that India has entered into a record 174 Advance Pricing Agreements (APAs) with Indian taxpayers in FY 2024-25. These include Unilateral APAs (UAPAs), Bilateral APAs (BAPAs) and Multilateral APAs (MAPAs). With this, the total number of APAs since the inception of the programme has reached 815, comprising 615 UAPAs, 199 BAPAs and 1 MAPA.
This marks the highest number of APAs signed in a single financial year since the programme’s launch. Of the 174 APAs signed, 65 were BAPAs, the highest number of BAPAs finalised in any year so far. These were a result of Mutual Agreements with India’s treaty partners, including Australia, Japan, South Korea, The Netherlands, New Zealand, Singapore, UK, and US.
The APA Scheme aims to provide certainty to taxpayers in the area of transfer pricing by specifying pricing methods and determining the arm’s length price of international transactions in advance for up to five years. BAPAs offer the added benefit of protection against potential or actual double taxation.
