CBDT, Japanese firm subsidiary sign advance pricing agreement

New Delhi, March 7 (IANS) The Central Board of Direct Taxes (CBDT) on Tuesday said it has entered into a bilateral Advance Pricing Agreement (APA) with rollback provision with a Japanese firm’s subsidiary.

The signing of the agreement took place on Monday, a CBDT statement said, adding this has taken the total number of APAs it has signed to 141 and expects more APAs to be concluded and signed before the end of the current fiscal.

“With this signing, the total number of bilateral APAs with Japanese subsidiaries has reached five, all with rollback provisions. Four APAs out of these five have been signed in the current financial year. All these five bilateral APAs are with Japanese trading companies (Sogo Soshas),” it said.

Certainty in tax treatment for Sogo Soshas has been a long standing demand of the Japanese industry. The bilateral signing of APAs in this sector provides tax certainty up to nine years in each of these cases.