CBDT has entered into 219 Advance Pricing Agreements (APAs) in FY 2025-26, taking the total number of APAs since inception past 1,000. The year also saw India sign its first-ever bilateral APAs with France, Ireland, Indonesia, and Sweden.
India’s Central Board of Direct Taxes (CBDT), under the Ministry of Finance’s Department of Revenue has announced the signing of a record 219 Advance Pricing Agreements (APAs) with Indian taxpayers in FY 2025-26. This total includes both Unilateral APAs (UAPAs) and Bilateral APAs (BAPAs), bringing the cumulative APA count to 1,034—comprising 750 UAPAs and 284 BAPAs—since the launch of the APA programme.
This year, CBDT signed 84 BAPAs, surpassing the previous year’s record of 65 BAPAs. The agreements were executed following Mutual Agreements with 13 of India’s treaty partners: the US, Finland, the UK, Singapore, Japan, South Korea, Australia, Denmark, Sweden, France, Indonesia, Ireland, and New Zealand. Notably, 2025-26 marks India’s first bilateral APAs with France, Ireland, Indonesia, and Sweden.
CBDT has consistently maintained high APA activity, signing 174 APAs in FY 2024-25 and 125 APAs in FY 2023-24.
The APA programme is complemented by Safe Harbour Rules, which provide a faster, lower-cost route to transfer pricing certainty. Introduced in 2013, the Safe Harbour framework sets fixed margins for specific international transactions across twelve categories, including IT and software services, IT-enabled services, KPO, contract R&D, intra-group financing, guarantees, auto components, low value-adding services, and certain diamond industry transactions.
The Finance Act 2026 enhanced Safe Harbour Rules by consolidating multiple technology service segments into a single “Information Technology Services” category with a uniform 15.5% margin and increasing the eligibility threshold from INR 300 crore to INR 2,000 crore. The amendments also introduce a more system-driven and automated framework, reducing the need for detailed scrutiny and administrative intervention.
Together, the APA Scheme and Safe Harbour Rules aim to provide transfer pricing certainty by determining arm’s length prices for international transactions in advance for up to five years. Bilateral APAs additionally offer protection against potential or actual double taxation. CBDT highlighted the collaborative role of taxpayers as key stakeholders in the programme’s continued success.
This announcement was made on 31 March 2026.
